Henderson v. Morgan

United States Supreme Court

426 U.S. 637 (1976)

If the defendant is not advised of a significant element of the offense with which he is charged, a guilty plea is not knowing and voluntary under the Fourteenth Amendment’s Due Process Clause.

Relevant Facts

Morgan (the defendant) was confined in an institution at a young age after being labeled “retarded”. Upon release, the defendant went to work on Ada Francisco’s farm. An argument ensued, and the defendant and Francisco got into an altercation in which the defendant stabbed Francisco to death. The defendant was charged with first-degree murder and was offered a plea deal of 25 years imprisonment in exchange for a guilty plea to second-degree murder, which the defendant accepted. However, the defendant’s attorney failed to clarify the intent required for second-degree murder, and the judge failed to explain the elements of the offense and failed to ask whether the defendant was advised of the elements. The defendant challenged the validity of his guilty plea, claiming that he would not have pleaded guilty if he knew that intent to cause the victim’s death was an element of second-degree murder.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 22, 2020

Judicial Opinion

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Procedural History

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Citations

426 U.S. 637 (1976)