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Iowa v. Tovar
| Iowa v. Tovar | |
|---|---|
 | |
| Argued January 21, 2004 Decided March 8, 2004 | |
| Full case name | Iowa v. Tovar |
| Docket no. | 02-1541 |
| Citations | 541 U.S. 77 (more) 124 S. Ct. 1379 |
| Argument | Oral argument |
| Case history | |
| Prior | first OWI conviction: 1996 second OWI: 1998 third OWI indictment: 2000; motion to reduce the charges denied, 2001; conviction, 2001; affirmed (Iowa Court of Appeals); reversed, 656 N.W.2d 112 (Iowa 2003); certiorari granted, 539 U.S. 987 (2003) |
| Holding | |
| A guilty plea by a pro se defendant may be accepted, and their right to counsel validly waived, if 1) they are informed of the nature of the charges against them, of their right to be counseled regarding their plea, and of the range of allowable punishments, taking into account 2) the defendant's education or sophistication and the complex or easily grasped nature of the charge. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Ginsburg (unanimous) |
| Laws applied | |
| U.S. Const. amend. VI | |
Iowa v. Tovar, 541 U.S. 77 (2004),[1] was a unanimous decision of the Supreme Court of the United States that clarified how well-informed a defendant had to be to waive their right to counsel under the Sixth Amendment.[2] The defendant in this case had waived his right to counsel and pled guilty to drunk driving, and then had been convicted of drunk driving twice more, with sentences increasing as his convictions piled up. He argued that the judge in the first case had not explained that multiple drunk driving convictions would lead to more severe sentences, so his waiver of counsel had been invalid. The Supreme Court disagreed, saying that the judge's warnings had been adequate, and the defendants' waiver was "knowing, voluntary, and intelligent."[1]
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