Commonwealth v. Wiswall

Henderson v. Morgan, 426 U.S. 637 (1976), established that a plea of guilty could not be regarded as having been made intelligently and voluntarily unless the defendant received adequate notice of each of the critical elements of the offense. The case does not require, however, that, in every instance, the judge explicate all the elements of the crime (426 U.S. at 647 n.18). Thus, a plea can be shown to be voluntary if the record shows: “(1) an explanation by the judge of the elements of the crime; or (2) a representation that counsel has explained to the defendant the elements he admits by…