Marshall v. Lonberger

Defendant was indicted by an Ohio grand jury for two counts of aggravated murder to which he pleaded not guilty. The State sought to prove a “specification” of prior conviction that would raise defendant’s applicable punishment to death. The State offered defendant’s conviction statement and corresponding record from an Illinois circuit court where he pleaded guilty to four charges, including aggravated battery. Before admitting this evidence, the Ohio trial court conducted a hearing confirming that defendant’s guilty pleas to the Illinois charges were knowing and voluntary. Defendant was sentenced to death. After the Ohio Court of Appeals affirmed, defendant sought a writ of habeas corpus. The Court upheld his conviction, determining that every effort was taken to protect defendant’s constitutional rights. To waive one’s rights, one’s guilty plea must be knowing, intelligent, and voluntary. The federal habeas courts were bound to the factual conclusions of the Illinois court records. Defendant’s Illinois convictions demonstrated his experience with the criminal justice system. Defendant did not have such an incomplete understanding of the Illinois charges that his guilty pleas were invalid as entered. Because one with defendant’s intelligence and experience would have easily understood that the Ohio trial judge was inquiring as to how he would plead, defendant was not misled.

“We greatly doubt that Congress, when it used the language ‘fairly supported by the record’ considered ‘as a whole’ intended to authorize broader federal review of state-court credibility determinations than are authorized in appeals within the federal system itself.” p.434-35