Law School Case Brief
Boykin v. Alabama - 395 U.S. 238, 89 S. Ct. 1709 (1969)
A defendant who enters a guilty plea simultaneously waives several constitutional rights, including his privilege against compulsory self-incrimination, his right to trial by jury, and his right to confront his accusers. For this waiver to be valid under the Due Process Clause, it must be an intentional relinquishment or abandonment of a known right or privilege. Consequently, if a defendant's guilty plea is not equally voluntary and knowing, it has been obtained in violation of due process and is therefore void. Moreover, because a guilty plea is an admission of all the elements of a formal criminal charge, it cannot be truly voluntary unless the defendant possesses an understanding of the law in relation to the facts.
Petitioner Boykin, a 27-year-old Negro, who was represented by appointed counsel, pleaded guilty to five indictments for common-law robbery. The judge asked no questions of Boykin concerning his plea, and Boykin did not address the court. Under Alabama law providing for a jury trial to fix punishment on a guilty plea, the prosecution presented eyewitness testimony and Boykin’s counsel cursorily cross-examined. Boykin did not testify; no character or background testimony was presented for him; and there was nothing to indicate that he had a prior criminal record. The jury found Boykin guilty and sentenced him to death on each indictment. The Alabama Supreme Court reviewed the sentences under the State's automatic appeal statute for capital cases, which requires the reviewing court to comb the record for prejudicial error even though not raised by counsel. Boykin did not raise the question of the voluntariness of his guilty plea and the State Supreme Court did not pass on that question, though a majority of the court explicitly considered it in affirming his sentences of death. The United States Supreme Court granted the petition for certiorari.
Was an affirmative showing of voluntariness on the record necessary in order to conclude that Boykin had waived his constitutional rights?
Although the issue of voluntariness of the plea had not been raised, the United States Supreme Court chose to consider the issue under the plain error doctrine as stated in Ala. Code, tit. 15, § 382(10) (1958). The Court reversed Boykin’s conviction because the record contained no showing that his guilty plea was voluntary. An affirmative showing of voluntariness on the record was necessary in order to conclude that Boykin had waived his constitutional rights
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