Iowa v. Tovar

The Sixth Amendment safeguards to an accused who faces incarceration the right to counsel at all critical stages of the criminal process. Maine v. Moulton, 474 U. S. 159, 170 (1985); United States v. Wade, 388 U. S. 218, 224 (1967). The entry of a guilty plea, whether to a misdemeanor or a felony charge, ranks as a “critical stage” at which the right to counsel adheres. Argersinger v. Hamlin, 407 U. S. 25, 34 (1972); White v. Maryland, 373 U. S. 59, 60 (1963) (per curiam). Waiver of the right to counsel, as of constitutional rights in the criminal process generally, must be a “knowing,…