Henderson v. Morgan

426 U.S. 637 (1976)

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Henderson v. Morgan

United States Supreme Court
426 U.S. 637 (1976)

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Facts

Morgan (defendant) was labeled “retarded” and confined to an institution at a young age. Upon release, Morgan went to work on Ada Francisco’s farm. After arguing with Francisco, Morgan went to collect his pay and leave. An altercation ensued, and Morgan stabbed Francisco to death. Morgan was charged with first-degree murder. The prosecution offered a plea deal of 25 years imprisonment in exchange for a guilty plea to second-degree murder. Morgan’s attorneys did not clarify the intent required for that offense. Morgan entered a guilty plea. The judge did not explain the elements of the offense or ask if Morgan had been so advised. At sentencing, Morgan’s attorneys claimed that Morgan never intended to harm Francisco. Morgan later secured an evidentiary hearing to challenge the validity of the guilty plea. Morgan claimed he would not have pleaded guilty if he knew that intent to cause the victim’s death was an element of second-degree murder.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Dissent (Rehnquist, J.)

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