Francisco German Alvarez v. United States
DueProcess HabeasCorpus JusticiabilityDoctri
In determining the voluntariness of a guilty plea, did the Ninth Circuit improperly apply the competence-to-stand-trial standard instead of the Boykin/Ruiz voluntariness analysis?
QUESTION PRESENTED FOR REVIEW In Boykin v. Alabama, 395 U.S. 238, 242-43 (1969), this Court underscored the seriousness and gravity of a guilty plea where a defendant waives the Fifth Amendment right to the privilege against self-incrimination and the Sixth Amendment right to trial by jury. Later, in United States v. Ruiz, 536 U.S. 622, 629 (2002), this Court added: Given the seriousness of the matter, the Constitution insists, among other things, that the defendant enter a guilty plea that is "voluntary" and that the defendant must make related waivers "knowingly, intelligently, [and] with sufficient awareness of the relevant circumstances and likely consequences." Emphasis added. Therefore, the question presented by Alvarez regarding the voluntariness of his guilty plea is: In determining the questioned voluntariness of the guilty plea, did the Ninth Circuit impermissibly create confusion when it misapplied the lower standard for competence to stand trial instead of the more demanding Boykin/Ruiz voluntariness analysis to Alvarez’s guilty plea?