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.
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.