Bradshaw v. Stumpf

Defendant was indicted on several charges arising out of a robbery and murder, including an aggravated murder charge that made the Defendant eligible for the death penalty. The Defendant accepted a plea deal that still made him eligible for the death penalty and the Defendant was sentenced to death. The United States Court of Appeals for the Sixth Circuit determined that the Defendant’s guilty plea was invalid because it had not been entered into knowingly and intelligently. More specifically, the Court of Appeals believed that the Defendant had pleaded guilty to aggravated murder without “understanding that specific intent to cause death was a necessary element of the charge under Ohio Law.” The Supreme Court, however, concluded that the Court of Appeals findings were without support. The Court agreed the guilty plea standard is not met when a defendant pleads guilty to a crime without having been informed of the crime’s elements. In this case, however, the Court found that the Defendant had been properly informed by his attorney prior to pleading guilty. The Court pointed to the record, where the Defendant’s attorneys represented that the Defendant was aware of the elements of his aggravated murder charge, which the Defendant confirmed to be accurate. The Court then held that when a defendant is represented by competent counsel, the court may usually rely on that counsel’s assurance that the defendant has been properly informed of the nature of the elements of the charge to which he is pleading guilty.

“While the court taking a defendant’s plea is responsible for ensuring a record adequate for any review that may be later sought, the United States Supreme Court has never held that the judge must himself explain the elements of each charge to the defendant on the record. Rather, the constitutional prerequisites of a valid plea may be satisfied where the record accurately reflects that the nature of the charge and the elements of the crime were explained to the defendant by his own, competent counsel.” p.183