Boykin v. Alabama Case Brief

Why is the case important?

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

Facts of the case

“In the spring of 1966, a series of armed robberies were committed in Mobile, Alabama. In two instances a gun was fired, and one person was injured when the bullet ricocheted off the floor. The petitioner, 27-year-old Edward Boykin, Jr., was arrested on five counts of robbery. He was provided with court-appointed counsel and pled guilty on all five counts. The judge did not ask Boykin whether he entered his plea knowingly and voluntarily, nor does the record show that Boykin was aware of his rights to trial by jury and to confront his accusers.Pursuant to Alabama law, a jury trial determined Boykin’s punishment. Boykin did not testify and offered no evidence regarding his character. There was no evidence of a prior criminal record. The jury sentenced the petitioner to death on all five counts. The Supreme Court of Alabama affirmed the death sentence, but three justices dissented on the grounds that the record did not show the petitioner entered his plea knowingly and voluntarily.”

Question

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

Answer

“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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    Conclusion

    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

    • Case Brief: 1969
    • Petitioner: Edward Boykin, Jr.
    • Respondent: Alabama
    • Decided by: Warren Court

    Citation: 395 US 238 (1969)
    Argued: Mar 4, 1969
    Decided: Jun 2, 1969
    Granted Oct 14, 1968