Tuesday, November 5, 2013

Henderson v. Morgan case brief

Henderson v. Morgan case brief summary
426 U.S. 637 (1976)

Petitioner corrections officer challenged the judgment of the United States Court of Appeals for the Second Circuit which affirmed the holding of a lower court that as a matter of law the guilty plea of respondent convict was involuntary and had to be set aside. Respondent had pleaded guilty to second-degree murder and was sentenced to an indeterminate term of imprisonment of 25 years to life.


  • The court affirmed the judgement of the lower court because it determined that there was nothing in the record that could serve as a substitute for either a finding after trial, or a voluntary admission, that respondent had the requisite intent. 
  • Defense counsel did not purport to stipulate to that fact; they did not explain to him that his plea would be an admission of that fact; and he made no factual statement or admission necessarily implying that he had such intent. 
  • The court found that under those circumstances it was impossible to conclude that respondent's plea to the unexplained charge of second-degree murder was voluntary.


The court affirmed the judgment of the lower court.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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