State Ex Rel. Lawrence v. Burke

The referee recognized that there is a fundamental, absolute rule that a defendant in a criminal case shall be informed of the charge against him and of the fact that he is entitled to assistance of counsel. The controlling question, then, is whether the evidence sustains the referee’s finding that Paul Lawrence knew or should have known of his right to be represented by counsel and that he intelligently and competently waived his right to be so represented at the time he pleaded guilty.

The referee’s findings of fact cover petitioner’s history, conduct, career, and intelligence, so far as…