State v. Roberts

Syllabus

The defendant appealed, on the granting of certification, from the judg- ment of the Appellate Court, which had affirmed his conviction, on pleas of guilty, of reckless endangerment in the second degree, threatening in the first degree, and intimidation based on bigotry or bias in the third degree. The defendant claimed that the Appellate Court had improperly upheld the trial court's denial of his motion to withdraw his pleas because, during the plea canvass, the trial court did not specifically ask him whether he was knowingly and voluntarily waiving his constitutional rights to a jury trial, to confront his accusers, and against self-incrimination, which he claimed was required by Boykin v. Alabama (395 U.S. 238). Held: The Appellate Court properly upheld the trial court's denial of the defen- dant's motion to withdraw his pleas, as the plea canvass of the defendant in this case was constitutionally adequate, even though it presented a very close question and was contrary to best practices. Boykin requires only that the record affirmatively disclose that a defendant has entered his plea knowingly and voluntarily for the plea to be constitution- ally valid, and there is no requirement that a plea canvass include enumeration of each of the three constitutional rights identified in Boykin. Moreover, in order to determine whether a defendant's guilty plea was knowing and voluntary, a reviewing court must consider the totality of the circumstances surrounding the plea canvass, and, under the totality of the circumstances of the present case, the plea canvass of the defendant was constitutionally adequate. Specifically, during the plea canvass, the defendant confirmed that counsel had explained to him the rights that he was waiving by pleading guilty, that he had been afforded enough time to speak with counsel about his decision to plead guilty, and that he was satisfied with counsel's representation, all of which were sufficient to demonstrate the defendant's understan