Supreme Court of the United States

Parke v. Raley

December 1, 1992506 U.S. 20

Summary

The Court held that due process permits Kentucky to presume the regularity of final convictions and impose a burden of production on a recidivism defendant challenging prior guilty pleas under Boykin. It also held that the prosecution need not establish the validity of those pleas by clear and convincing extrinsic evidence when transcripts are unavailable, and that the record supported the Kentucky courts' determination that Raley's 1981 plea was knowing and voluntary. Justice O'Connor wrote for eight Justices. Justice Blackmun concurred in the judgment without joiners, emphasizing that he accepted the burden-shifting procedure only because Kentucky's persistent-felony-offender provision enhances punishment rather than creates a separate offense.

Holding

  • Allocation of the burden of production in a collateral challenge to a prior guilty plea used for sentence enhancement.. The Due Process Clause permits a State to impose a burden of production on a recidivism defendant challenging a prior conviction under Boykin.
  • The constitutionally required measure of proof when the prosecution bears the ultimate burden of establishing a prior plea's validity.. Due process does not require the prosecution to prove a prior conviction's validity by clear and convincing extrinsic evidence merely because the plea transcript is unavailable.
  • Whether Raley's 1981 plea was valid on the record presented.. The Kentucky courts' factual determinations were fairly supported by the record, and their conclusion that Raley understood the consequences of his 1981 plea was not erroneous.

Docket 91-719

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