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337 N.W.2d 664

State v. Motl

Supreme Court of Minnesota

Decided August 19, 1983

Supreme Court of Minnesota · decided 1983-08-19

Key passage — most relied on by later courts

“be conscious of the potential for confusion when they issue en masse warnings to groups containing persons charged with non-criminal petty misdemeanors and those charged with criminal misdemeanors. Such warnings must be supplemented by individual questioning to insure that defendants understand which portions of the warnings apply to them.”

quoted by 1 later decision, including State v. Foncesa

Relies on Boykin v. Alabama

Good law ✅— No negative treatment on recordhow we know

Decided 1983-08-19

How this case has been cited

Cited by 17 later decisions — most recently February 2011

17 state decisions

1401983199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

WAHL, Justice

¶1(dissenting).

¶2Because I conclude that the record before us does not affirmatively reveal a knowing and intelligent waiver of the right to counsel, I respectfully dissent.

¶3A misdemeanor defendant must be informed of his right to counsel, Minn.R. *667Crim.P. 5.01(b) and 15.02, and must make a knowing and intelligent waiver of that right on the record before pleading guilty. Boykin v. Alabama, 395 U.S. 238, 242, 89 S.Ct. 1709, 1711, 23 L.Ed.2d 274 (1969). The trial court did not make an adequate effort here to determine whether appellant understood that he had a right to counsel, nor did it specifically inquire whether appellant waived that right. The court instead generally inquired whether defendant waived his “constitutional rights.”

¶4The group of defendants here, advised en masse of their constitutional rights under Minn.R.Crim.P. 15.03, subd. 1, contained both persons charged with noncriminal petty misdemeanors and those charged with criminal misdemeanors. Under these circumstances, the trial court’s explanation of the differing rights available to the two types of charges could likely cause confusion. The court should have thereafter individually advised appellant whether the charge facing him was a petty misdemeanor or a misdemeanor and should have specifically inquired whether appellant waived the right to counsel. The majority opinion concedes that this procedure should be followed but does not require such in this case. Because I perceive no reason to except this case from the requirement of a record showing a valid waiver of the right to counsel, I would reverse the conviction.

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