Iowa v. Tovar
United States Supreme Court
541 U.S. 77 (2004)
Relevant factsFree
Tovar (defendant) pled guilty while representing himself, and the Iowa Supreme Court reversed his conviction, holding that the federal Constitution required the trial court to give specific warnings about the value of having counsel before accepting a waiver of the right to counsel, and that because no such warnings were given, Tovar's waiver was invalid.
IssueFree
Whether the Sixth Amendment requires specific warnings regarding the usefulness of counsel before a pro se defendant may plead guilty.