Boykin v. Alabama, 395 U.S. 238, 242 (1969)

The central issue in the Boykin case was the responsibility of a criminal court to safeguard the rights of the accused. Edward Boykin, a twenty-seven-year-old African-American man, was sentenced to death by an Alabama judge in 1966 after pleading guilty to five counts of armed robbery, at the time punishable by execution according to state law. In his automatic appeal to the Alabama Supreme Court, Boykin’s attorneys argued that a death sentence for armed robbery constituted cruel and unusual punishment. The Court rejected the appeal but expressed doubts as to whether the trial judge had acted properly in accepting the defendant’s guilty plea without questioning him or requiring him to address the court.

Boykin then appealed his case to the U.S. Supreme Court, which in June 1969 ruled by seven-to-two majority that the judge erred in allowing the guilty plea without requiring Boykin to confirm it himself, stating that the standards for evaluating whether a defendant knowingly and voluntarily enters a guilty plea should at least equal the standards for determining a defendant’s mental competence to stand trial. Writing for the majority, Justice William O. Douglas opined that in order to meet these standards, the trial record must clearly show that the defendant personally waived his or her constitutional rights. The Boykin decision thus joined the Miranda and Gideon decisions in expanding and clarifying the responsibility of courts to ensure the rights of criminal defendants, thereby reinforcing constitutional guarantees of due process, trial by jury, and protection from self-incrimination.

MICHAEL H. BURCHETT

References and Further Reading

• Horn, Maurita Elaine, Confessional Stipulations: Protecting Waiver of Constitutional Rights, University of Chicago Law Review 61 (Winter 1994): 1:225–51
• Kersch, Kenneth I. Constructing Civil Liberties: Discontinuities in the Development of American Constitutional Law. New York: Cambridge University Press, 2004

Cases and Statutes Cited

• Gideon v. Wainwright, 372 U.S. 335 (1963) 
• Miranda v. Arizona, 384 U.S. 436 (1966) 

See also Capital Punishment and Right of Appeal; Capital Punishment: Proportionality; Guilty Plea; Jury Trial Right; Miranda Warning; Plea Bargaining; Race and Criminal Justice; Self-Incrimination: Miranda and Evolution