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Boykin v. Alabama

    Brief Fact Summary. Defendant was sentenced to death after pleading guilty to a series of robberies.

    Synopsis of Rule of Law. “[T]he record must show, or there must be an allegation and evidence which show, that an accused was offered counsel but intelligently and understandingly” pleaded guilty.

    Facts. Defendant Boykin was African-American charged with common-law robbery, which carried a death sentence in Alabama. He was appointed counsel and pleaded guilty. Under Alabama law, the jury still provided a sentence of death.

    Issue. Whether “the record must show, or there must be an allegation and evidence must show, that an accused” made a voluntary guilty plea.

    Held. Yes. The Supreme Court of the United States held that a guilty plea is “more than a confession” and so the standards of “reliable determination on the voluntariness [sic] issue which satisfies the constitutional rights of the defendant” applied to a guilty plea as well. Because several rights were “involved in a waiver that takes place when a plea of guilty is entered in a state criminal trial,” the Supreme Court could not “presume a waiver of these.


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