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A plea may be involuntary either because the accused does not understand the nature of the constitutional protections that he is waiving or because he has such an incomplete understanding of the charge that his plea cannot stand as an intelligent admission of guilt. Without adequate notice of the nature of the charge against him, or proof that he in fact understood the charge, the plea cannot be voluntary in this latter sense.
Respondent was indicted for first-degree murder, but by agreement with the prosecution and on counsel's advice respondent pleaded guilty to second-degree murder and was sentenced. Subsequently, after exhausting his state remedies in an unsuccessful attempt to have his conviction vacated on the ground that his guilty plea was involuntary, respondent filed a habeas corpus petition in Federal District Court, alleging that his guilty plea was involuntary because, inter alia, he was not aware that intent to cause death was an element of second-degree murder. The District Court ultimately heard the testimony of several witnesses, including respondent and his defense counsel in the original prosecution; and the transcript of the relevant state-court proceedings and certain psychological evaluations of respondent, who was substantially below average intelligence, were made part of the record. On the basis of the evidence thus developed the District Court found that respondent had not been advised by counsel or the state court that an intent to cause death was an essential element of second-degree murder, and, based on this finding, held that the guilty plea was involuntary and had to be set aside. The Court of Appeals affirmed.
Was respondent’s guilty plea involuntary, thereby warranting the reversal of his conviction for second-degree murder?
According to the Court, a plea cannot support a judgment of guilt unless it was voluntary in a constitutional sense. Clearly, the plea could not be voluntary in the sense that it constituted an intelligent admission that he committed the offense unless the respondent received real notice of the true nature of the charge against him, the first and most universally recognized requirement of due process. In this case, the Court determined that there was nothing in the record that could serve as a substitute for either a finding after trial, or a voluntary admission, that respondent had the requisite intent. Defense counsel did not purport to stipulate to that fact; they did not explain to him that his plea would be an admission of that fact; and he made no factual statement or admission necessarily implying that he had such intent. The Court found that under those circumstances it was impossible to conclude that respondent's plea to the unexplained charge of second-degree murder was voluntary.