Henderson v. Morgan

Brief Fact Summary. Respondent sought to have his plea agreement vacated on the grounds that it was involuntary.

Synopsis of Rule of Law. A “plea [can] not be voluntary in the sense that it constituted an intelligent admission that [the defendant] committed the offense unless the defendant received ‘real notice of the true nature of the charge against him.’”

Facts. Respondent was indicted for first-degree murder. He agreed to a guilty-plea of second-degree murder. He subsequently filed a habeas corpus petition on the grounds that his guilty plea was involuntary because he was not aware that “intent to cause death was an element of second-degree murder.” Based on the evidence, the District Court found that the respondent had not been properly advised.

Issue. Whether the court “should examine the totality of the circumstances and determine whether the substance of the charge.