Bradshaw v Stumpf
In 1984, Stumpf waived his right to a jury trial and pled guilty to aggravated murder with the specification that the murder was committed to escape detection, apprehension, trial, and punishment for other offenses, including aggravated robbery and attempted aggravated murder. Following an evidentiary hearing and a mitigation hearing, a three-judge panel sentenced Stumpf to death. Under Ohio law, the aggravated murder statute required that “specific intent” be proved. At the evidentiary hearing, Stumpf and his attorneys argued that he did not shoot the victim and, indeed, that he was not present when the victim was shot. The state argued in response that Stumpf was the shooter, and the three-judge panel that heard the case adopted the state’s theory, finding that Stumpf was the actual shooter. At a later trial of Stumpf’s accomplice Wesley, however, the state presented the testimony of a jailhouse informant to establish that Wesley was the shooter.
As a result, Stumpf filed a motion for leave to withdraw his guilty plea or, in the alternative, to have the trial court set aside his death sentence and grant him a new sentencing hearing. The motion was summarily denied and the Ohio Supreme Court affirmed the order at the same time it affirmed Stumpf’s conviction on direct appeal.
After unsuccessfully pursuing state post-conviction relief, Stumpf filed a petition for a writ of habeas corpus in federal court. The district court denied relief on his claims, but granted a certificate of appealability on five issues. The Sixth Circuit Court of appeals held that the district court should have granted relief to Stumpf on either or both of two alternative grounds: (1) that his guilty plea was unknowing and involuntary because he was not aware that specific intent was an element of the crime to which he pleaded guilty; and/or (2) that Stumpf’s due process rights were violated by the state’s deliberate action in securing convictions of both Stumpf and Wesley for the same crime, using inconsistent theories.
Questions Presented:
1. Is a representation on the record from defendant's counsel and/or the defendant that defense counsel has explained the elements of the charge to the
defendant, sufficient to show the voluntariness of the guilty plea under Henderson v. Morgan, 426 U.S. 637, 647 (1976)?
2. Does the Due Process Clause require that a defendant's guilty plea be vacated when the State subsequently prosecutes another person in connection with the crime and allegedly presents evidence
at the second defendant's trial that is inconsistent with the first defendant's guilt?
