State of Connecticut v. David D. Roberts

Summary

The Connecticut Supreme Court affirmed the defendant's convictions and the denial of his motion to withdraw guilty pleas. The court held that the plea canvass was constitutionally adequate under Boykin v. Alabama because, considering the totality of the circumstances, the record affirmatively demonstrated that the pleas were knowing and voluntary, although the canvass was close to constitutionally inadequate and contrary to best practices.

Holdings

1. Boykin does not require a trial court to expressly enumerate each of the three rights identified in Boykin or obtain a separate on-the-record waiver of each right. It requires an affirmative record showing that the defendant entered the guilty plea knowingly and voluntarily.
2. The plea canvass was constitutionally adequate under the totality of the circumstances, although it presented a very close question and fell at the outermost boundary of what Boykin permits.
3. As the best practice for ensuring a defendant’s understanding of the consequences of a guilty plea, trial courts should personally inquire into all five rights enumerated in Practice Book § 39-19 (5), including the rights to a jury trial, confrontation, and against self-incrimination.

Questions Presented

1. Whether the trial court’s plea canvass was constitutionally adequate under Boykin v. Alabama even though the court did not specifically enumerate and obtain separate waivers of the rights against self-incrimination, to a jury trial, and to confront one’s accusers.
2. Whether the defendant was entitled to withdraw his guilty pleas because the record did not affirmatively disclose that the pleas were knowing and voluntary.

Disposition

affirmed