Tracy G. Hutton, Petitioner v. State of Alaska, Respondent

Summary

The Alaska Supreme Court held that appellate review of a defendant's waiver of the right to a jury trial is a mixed question of law and fact—factual findings are reviewed for clear error and the legal conclusion de novo—and found that Hutton’s waiver was constitutionally defective because he was not advised of an essential element of the offense, reversing the Court of Appeals and remanding for a new trial on Count III.