Bradshaw v. Stumpf

In Bradshaw v. Stumpf (2005) 545 U.S. 175, a defendant argued that his guilty plea was invalid because he was unaware of all the elements of the charge to which he pled. The record contained a recitation by defense counsel that they had explained the charges and the defendant's affirmative statement that he had discussed the charges with counsel. Under these circumstances, the plea was valid. The United States Supreme Court stated, "we have never held that the judge must himself explain the elements of each charge to the defendant on the record. Rather, the constitutional prerequisites of a valid plea may be satisfied where the record accurately reflects that the nature of the charge and the elements of the crime were explained to the defendant by his own, competent counsel." (Id. at p. 183.) The Supreme Court addressed the issue of the voluntariness of a guilty plea. The Court reiterated that, "where a defendant pleads guilty to a crime without having been informed of the crime's elements . . . the plea is invalid." Id. at 183. It stated, however, that: "Where a defendant is represented by competent counsel, the court usually may rely on that counsel's assurance that the defendant has been properly informed of the nature and elements of the charge to which he is pleading guilty." Id.