Ernst, Plaintiff in Error v. State, Defendant in Error

Summary

The Wisconsin Supreme Court affirmed the order denying Ernst's postconviction motion to withdraw his guilty pleas. Applying the 'manifest injustice' test, the court held the defendant failed to prove by clear and convincing evidence either ineffective assistance of counsel or an involuntary plea entered without knowledge of the charges or sentence. Although the court announced that Boykin v. Alabama makes the Rule 11 plea-taking procedures of McCarthy v. United States binding on Wisconsin courts as a matter of federal constitutional law — displacing State v. Strickland's contrary presumption and adding a mandatory sixth inquiry standard — it held those requirements apply only prospectively and therefore did not invalidate this pre-Boykin plea. No separate opinions were filed.