Does a stipulation of facts constitute a de facto guilty plea?

MultiRegion, United States of America

The following excerpt is from Adams v. Peterson, 968 F.2d 835 (9th Cir. 1992):

Adams argues that his stipulation of facts at trial constituted a de facto guilty plea and that he was therefore entitled to the procedural protections attendant to the entering of such a plea. Specifically, he claims that he was entitled to be advised by the judge in open court of his constitutional rights (a) against compulsory self-incrimination, (b) to be tried by a jury, and (c) to confront his accusers, and that the court had a constitutional obligation to establish on the record that he voluntarily and intelligently waived these rights. See Boykin v. Alabama, 395 U.S. 238, 243, 89 S.Ct. 1709, 1712, 23 L.Ed.2d 274 (1969). 1 While we agree that a stipulated-facts proceeding is subject to certain constitutional restrictions, see infra Part III, we are not persuaded that the stipulation at issue was a de facto guilty plea.

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