In the United States v. Timmreck case of 1978, the Supreme Court ruled that a technical error in a defendant's plea agreement does not automatically entitle them to have their conviction overturned on collateral review. The defendant, Richard Timmreck, had pleaded guilty to charges related to drug distribution but later sought to have his conviction vacated due to an error in his plea colloquy: he was incorrectly informed about the mandatory special parole term for his offense. However, since this mistake did not result in "a complete miscarriage of justice" or lead him "to plead guilty when he would otherwise go trial," as per Justice Thurgood Marshall’s opinion for unanimous court decision; it was held that such minor errors do not undermine the voluntary and intelligent nature of pleas and thus are insufficient grounds for overturning convictions on collateral attack.

In the dissenting opinion for United States v. Timmreck, Justice Thurgood Marshall argued that a defendant should be allowed to challenge his conviction if he can prove that an error in his plea colloquy affected his decision to plead guilty. He disagreed with the majority's view that such errors are harmless and do not violate Rule 11 of Federal Rules of Criminal Procedure unless they result in "a complete miscarriage of justice." Instead, he believed any violation of Rule 11 is inherently prejudicial because it undermines the defendant's ability to make an informed decision about pleading guilty. Therefore, according to Justice Marshall, defendants who can show their pleas were influenced by these violations should have their convictions overturned regardless of whether they suffered additional harm or prejudice as a result.