Henderson v. Morgan
426 U.S. 637 (1976)
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Rule of Law:
A guilty plea is involuntary under the Due Process Clause if the defendant lacks adequate notice of the critical elements of the offense to which he is pleading. For a charge of second-degree murder, the intent to cause the victim's death is such a critical element.
Facts:
- Respondent Henderson, a 19-year-old with a substantially below-average intelligence (IQ between 68-72), worked as a farm laborer for Mrs. Ada Francisco.
- Following an argument, Mrs. Francisco threatened to have Henderson returned to a state institution for individuals with developmental disabilities.
- Henderson decided to run away and, during the night, entered Mrs. Francisco's bedroom with a knife, planning to collect wages he believed he was owed before leaving.
- When Mrs. Francisco awoke and began to scream, Henderson stabbed her, resulting in her death.
- Henderson was promptly arrested after a car accident while fleeing the scene.
- At Henderson's sentencing hearing, his own defense attorney stated that Henderson 'meant no harm to that lady' when he entered her room.
Procedural Posture:
- In 1965, Henderson was indicted for first-degree murder in a New York state trial court and subsequently pleaded guilty to the reduced charge of second-degree murder.
- In 1970, Henderson challenged his conviction in New York state courts, arguing his plea was involuntary; the state courts denied relief.
- In 1973, Henderson filed a petition for a writ of habeas corpus in the U.S. District Court for the Northern District of New York, which initially denied the petition.
- The U.S. Court of Appeals for the Second Circuit reversed the District Court's denial and remanded the case for an evidentiary hearing.
- On remand, the District Court found that Henderson was never advised that intent was an element of the offense and granted the writ of habeas corpus, holding the plea was unconstitutional.
- The U.S. Court of Appeals for the Second Circuit affirmed the District Court's decision, and the U.S. Supreme Court granted certiorari to review the case.
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Issue:
Does a defendant's guilty plea to second-degree murder violate the Due Process Clause if the defendant was not informed that intent to cause the death of the victim is an essential element of the offense?
Opinions:
Majority - Mr. Justice Stevens
Yes. A guilty plea is not voluntary in a constitutional sense unless the defendant received 'real notice of the true nature of the charge against him,' which includes an understanding of the critical elements of the offense. Here, Henderson's plea was involuntary because he was never informed that intent to cause death was a required element of second-degree murder. A plea is an admission of all the elements of a formal criminal charge; it cannot be truly voluntary if the defendant does not possess an understanding of the law in relation to the facts. An admission that he killed the victim does not necessarily admit he was guilty of second-degree murder, as a jury could have found him guilty of manslaughter. Given Henderson's unusually low mental capacity and the trial court's factual finding that the element of intent was never explained to him, it is impossible to conclude that his plea to the unexplained charge was voluntary.
Concurring - Mr. Justice White
Yes. A defendant's guilt can only be established by a verdict after trial or by the defendant's own solemn admission in open court that he is in fact guilty. A defendant cannot make a valid admission of guilt if he does not know the elements of the crime to which he is pleading, as his plea would not be an intelligent one. In this case, Henderson did not expressly admit intent, and his plea cannot be construed as an implied admission because he was never told intent was an element. A conviction cannot rest on strong evidence alone or on a lawyer's tactical decision; it must rest on a constitutionally valid establishment of guilt, which is absent here.
Dissenting - Mr. Justice Rehnquist
No. Under the 'totality of the circumstances' standard applicable to this pre-1969 plea, the plea was constitutionally valid. The majority improperly applies a requirement for a 'ritualistic litany' of legal elements, which is a more stringent standard that developed later. Henderson was represented by two competent attorneys who made a reasonable tactical judgment to plead to second-degree murder to avoid a conviction for first-degree murder. There was a strong factual basis for the plea, as a jury could easily have inferred the requisite intent from the multiple stabbings. The plea was voluntary, made after proper advice, and with a full understanding of the consequences (the sentence), which satisfied the constitutional standard of the time.
Analysis:
This decision significantly clarifies the 'voluntary and intelligent' standard for guilty pleas under the Due Process Clause. It establishes that a defendant's subjective awareness of the nature of the charge, including its critical legal elements, is a constitutional prerequisite for a valid plea. The ruling places a greater affirmative duty on defense counsel and trial courts to ensure that a defendant understands the law in relation to the facts they are admitting. Consequently, it has influenced the development of plea colloquy procedures, making them more thorough to create a clear record that the defendant has been properly informed.
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