In Hughes v. United States (1912), the U.S Supreme Court ruled that a defendant cannot withdraw their guilty plea after sentencing unless they can prove that the court violated Rule 32(d) of Federal Rules for Criminal Procedure, which allows withdrawal if it would prevent "manifest injustice". The case involved Charles Evans Hughes who had pleaded guilty to charges related to mail fraud and was sentenced by a lower court. He later sought to change his plea on grounds of being coerced into pleading guilty and not fully understanding the consequences. However, he failed in his appeal as he could not demonstrate any violation under Rule 32(d). This ruling set an important precedent regarding when defendants may retract their pleas post-sentencing.

In the dissenting opinion for Hughes v. United States, Justice Lamar argued that the majority's decision was incorrect because it failed to properly interpret and apply the law regarding land patents. He contended that a patent is not an absolute guarantee of ownership, but rather a presumption of validity subject to challenge in court if there are allegations of fraud or mistake. In this case, he believed there were sufficient grounds to question whether Hughes had obtained his land patent through fraudulent means. Therefore, he felt that the government should have been allowed to bring its suit against Hughes even though more than six years had passed since he received his patent.