State v. Roberts

Summary

The court held that the defendant's guilty pleas were constitutionally valid even though the plea canvass did not separately identify and obtain waivers of the rights to a jury trial, confrontation, and against self-incrimination. Applying the totality of the circumstances, the court found that the defendant's answers, counsel's participation, and the court's references to choosing between pleading guilty and proceeding to trial affirmatively established that the pleas were knowing and voluntary. The court nevertheless characterized the canvass as barely constitutionally sufficient and emphasized that trial courts should personally inquire into all specified plea-waiver rights. Justice Ecker, joined by Justice McDonald, concurred in the judgment but would require a more direct, individualized colloquy and treated the existing approach as overly deferential to deficient canvasses.