The Warren Court determined in Boykin v. Alabama (1969) that trial judges must ensure that criminal defendants understand and agree to the waiver of their constitutional rights when they plead guilty to criminal offenses. The case involved a twenty-seven-year-old African American defendant Edward Boykin, Jr., who pled guilty to five counts of robbery. The trial judge accepted Boykin’s plea without inquiring whether he understood the consequences of such action. A jury sentenced Boykin to death. The U.S. Supreme Court wrote that “it was error … for the trial judge to accept petitioner’s [Boykin’s] guilty plea without an affirmative showing that it was intelligent and voluntary.”