Moore v. Michigan - 355 U.S. 155 (1957)
U.S. Supreme Court
Moore v. Michigan, 355 U.S. 155 (1957)
Moore v. Michigan
Argued October 15-16, 1957
Decided December 9, 1957
355 U.S. 155
In a Michigan State Court in 1938, petitioner, a Negro then 17 years old and with only a seventh-grade education, said that he did not desire counsel, pleaded guilty to murder, and was sentenced to solitary confinement at hard labor for life without possibility of parole, the maximum sentence permitted under Michigan law. In 1950, he filed a delayed motion for new trial, as permitted by Michigan law, claiming that his conviction and sentence were invalid because he did not have the assistance of counsel at the time of his plea and sentence. This motion was denied by the trial court, and the State Supreme Court affirmed. It appeared from the record that, at the time of his trial, petitioner had several possible defenses involving questions of considerable technical difficulty obviously beyond his capacity to understand, and that his waiver of counsel and plea of guilty may have been induced by fear of mob violence resulting from statements made to him by the Sheriff.
Held: on the record in this case, petitioner had sustained his ultimate burden of proving that his plea of guilty was invalidly accepted without benefit of counsel, and that he did not validly waive his right to counsel; and the Judgment is reversed and the cause remanded for further proceedings. Pp. 355 U. S. 156-165.
(a) Petitioner's case falls within that class in which the intervention of counsel, unless intelligently waived, is an essential element of a fair hearing. P. 355 U. S. 159.
(b) The circumstances compel the conclusion that petitioner's rights could not have been fairly protected without the assistance of counsel. Pp. 355 U. S. 159-160.
(c) Where a person convicted in a state court has not intelligently and understandingly waived the benefit of counsel, and where the circumstances show that his rights could not have been fairly protected without counsel, the Due Process Clause invalidates his conviction. Pp. 355 U. S. 160-161.
(d) Where the right to counsel is of such critical importance as to be an element of Due Process under the Fourteenth Amendment, a finding of waiver is not lightly to be made. P. 355 U. S. 161.
(e) In this case, petitioner had the burden of showing, by a preponderance of the evidence, that he did not intelligently and understandingly waive his right to counsel. Pp. 355 U. S. 161-162.
(f) The fear of mob violence planted by the Sheriff in petitioner's mind raises an inference that his refusal of counsel was motivated by a desire to be removed from the local jail at the earliest possible moment; this is consistent with the trial judge's report of his interview with petitioner; and a rejection of federal constitutional rights motivated by fear cannot, in the circumstances of this case, constitute an intelligent waiver of counsel. Pp. 355 U. S. 162-165.
344 Mich. 137, 73 N.W.2d 274, reversed, and cause remanded.