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Keywords

attorneypleaguilty plea

attorneytrialpleaguilty plea

Related Cases

Dukes v. Warden, Conn. State Prison, 406 U.S. 250, 92 S.Ct. 1551, 32 L.Ed.2d 45

Facts

Charles Dukes was arrested and charged with narcotics violations and larceny. On May 16, 1967, he pleaded guilty on the advice of his attorney, Mr. Zaccagnino, who was also representing two girls in an unrelated case. After expressing dissatisfaction with his representation, Dukes attempted to withdraw his plea before sentencing, claiming he was pressured into it and that his attorney's conflict of interest rendered his plea involuntary. The court denied his request to withdraw the plea, and he was sentenced to five to ten years for the narcotics charge and two years for larceny.

On May 16, 1967, petitioner, on advice of counsel, pleaded guilty in the Superior Court of Hartford County, Connecticut, to charges of narcotics violation and larceny of goods. On June 16, 1967, before being sentenced, he informed the court that he had retained new counsel and desired to withdraw his plea and stand trial. The court refused to permit him to withdraw his plea and sentenced him to a term of five to 10 years on the narcotics charge and to a term of two years on the larceny charge.

Issue

Did the alleged conflict of interest of the petitioner's attorney render his guilty plea involuntary and unintelligent?

Rule

A guilty plea must be made voluntarily and intelligently, and a conflict of interest must result in ineffective assistance of counsel to invalidate a plea.

Analysis

The court found that Dukes was aware of the dual representation and did not express dissatisfaction with his attorney at the time of his plea. The court noted that Dukes had a lengthy conversation with his attorney before entering the plea and that he affirmed his satisfaction with the representation. The court concluded that there was no evidence that the alleged conflict of interest affected the voluntariness of Dukes' plea.

Conclusion

The U.S. Supreme Court affirmed the decision of the Connecticut Supreme Court, concluding that Dukes' claim lacked merit and that the alleged conflict of interest did not invalidate his guilty plea.

Who won?

The State of Connecticut prevailed because the court found no merit in Dukes' claim regarding the involuntariness of his plea.

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