SIM PlanetQuest (Space Interferometry Mission) is a space-borne Michelson interferometer for precision stellar astrometry, with a nine meter baseline, currently slated for launch in 2015. One of the principal science goals is the astrometric detection and orbit characterization of terrestrial planets in the habitable zones of nearby stars. Differential astrometry of the target star against a set of reference stars lying within a degree will allow measurement of the target star's reflex motion with astrometric accuracy of 1 micro-arcsecond in a single measurement. We assess SIM's capability for detection (as opposed to characterization by orbit determination) of terrestrial planets in the habitable zones of nearby solar-type stars. We compare SIM's performance on target lists optimized for the SIM and Terrestrial Planet Finder Coronograph (TPF-C) missions. Performance is quantified by three metrics: minimum detectable planet mass, number and mass distribution of detected planets, and completeness of detections in each mass range. Finally, we discuss the issue of confidence in detections and non-detections, and show how information from SIM's planet survey can enable TPF to increase its yield of terrestrial planets.