Summary
The Supreme Court of Indiana held that Keith Patton's guilty plea to attempted murder was invalid because he lacked real notice that specific intent to kill was an element of the offense, and the record did not establish harmlessness beyond a reasonable doubt. The court vacated the attempted-murder conviction and sentence while leaving Patton's 192-year sentence for his other convictions in effect. The court summarily affirmed the Court of Appeals on Patton's remaining claims.
Topics
Practice areas
Questions Presented
- Whether Patton's guilty plea to attempted murder was knowing, voluntary, and intelligent when he was not advised that specific intent to kill was an element of the offense.
- Whether the absence of notice of the specific-intent element was harmless beyond a reasonable doubt based on the guilty-plea or sentencing record.
- Whether the Indiana guilty-plea statute imposed greater notice obligations than the federal constitutional standard.
- Whether the reversal of the original murder conviction invalidated Patton's pleas to the other offenses.
- Whether several convictions violated double jeopardy.
- Whether trial counsel made improper statements about Patton's guilty plea during jury voir dire.
Holdings
- A guilty plea is constitutionally valid only if the defendant receives real notice of the true nature of the charge. Because specific intent to kill is a critical element of attempted murder, notice of that element was required; Patton's plea was invalid because the record showed neither adequate notice nor a valid basis to conclude that he understood the specific-intent requirement.
- When the defendant was not given and cannot be presumed to have received notice that specific intent is an element of attempted murder, relief is nevertheless unavailable if the guilty-plea or sentencing proceedings contain an unambiguous admission or other evidence demonstrating specific intent beyond a reasonable doubt.
- Indiana Code section 35-35-1-2 does not impose obligations on the court receiving a guilty plea, or confer rights on the defendant, greater than those required by Henderson v. Morgan.
Key quotations
“A defendant who pleads guilty need not be aware of each of the elements of the offense so long as the defendant receives real notice of the true nature of the charge or that the absence of such notice is harmless beyond a reasonable doubt.” (at 692)
“For purposes of the issue presented in Patton's case, we hold that failure of notice that specific intent is an element of attempted murder will constitute harmless error, i.e., be harmless beyond a reasonable doubt, where during the course of the guilty plea or sentencing proceedings, the defendant unambiguously admits to, or there is other evidence of, facts that demonstrate specific intent beyond a reasonable doubt.” (at 697)
“At the time Patton pled guilty to the offense of attempted murder, he did not know that specific intent to kill was an element of the offense.” (at 699)
Factual background
In 1983, Keith Patton fired a sawed-off shotgun into a parked vehicle, seriously injuring passenger Dietra Maxey and killing driver Michael Pack. Patton later pleaded guilty to attempted murder of Maxey and other offenses. During the guilty-plea proceedings, he was not advised that attempted murder required a specific intent to kill, and he admitted only that he knowingly attempted to kill Maxey by shooting at or against her; the record did not establish that he knew Maxey was in the vehicle or that he specifically intended to kill her.
Procedural history
Patton pleaded guilty in 1984 to murder, attempted murder, rape, criminal confinement, three counts of criminal deviate conduct, and dealing in a sawed-off shotgun. After this Court reversed the original murder conviction because Patton denied intent to kill, a jury retrial resulted in a murder conviction and a total sentence of 222 years. Patton later sought post-conviction relief; the Court of Appeals granted relief on the attempted-murder plea claim and rejected his other claims. The Supreme Court granted transfer, summarily affirmed the rejection of the three remaining claims, and vacated the attempted-murder conviction and sentence.
Remand instructions
The case was remanded to the trial court for further proceedings consistent with the opinion, including granting post-conviction relief and vacating Patton's conviction and sentence for attempted murder. Patton's 192-year sentence for his other convictions remained in effect.