LEJEUNE v. McLAUGHLIN, 296 Ga. 291

Lejeune pleaded guilty to murder in November 2005 and was sentenced to life without parole.
He filed a habeas corpus petition claiming his plea was invalid because he was not advised of his privilege against self-incrimination.
The habeas court denied relief, proceeding on the premise that the Warden bore the burden to prove voluntariness.
The Supreme Court vacated and remanded, overruling Purvis v. Connell, and held Lejeune bears the burden of proving the plea was not voluntary.
The Court concluded Purvis and related lines of Georgia habeas practice were based on a misreading of federal law (Boykin) and Parke v. Raley clarified the presumption of regularity.
The case was remanded for a new evidentiary hearing consistent with the opinion to determine whether Lejeune’s plea was knowingly and intelligently entered.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Burden of proof in habeas Boykin challenges	Lejeune	Warden	Lejeune bears the burden
Impact of Purvis overruled	Lejeune	Warden	Purvis overruled; burden shift changed
Presumption of regularity in final judgments	Lejeune	Warden	Presumption of regularity preserved; habeas burden aligned with Boykin-based principles
Adequacy of the record to show Boykin rights were explained	Lejeune	Warden	Remand for further hearing to develop record on Boykin rights waiver

Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (three Boykin rights acknowledged at plea)
Parke v. Raley, 506 U.S. 20 (U.S. 1992) (presumption of regularity in final judgments; limits of Boykin on collateral review)
Purvis v. Connell, 227 Ga. 764 (Ga. 1971) (State bears burden in Boykin challenges in habeas; presumption of regularity disputed)
Bowers v. Moore, 266 Ga. 893 (Ga. 1996) (acknowledges burden shifting in Boykin context)
Goodman v. Davis, 249 Ga. 11 (Ga. 1982) (harms or harmless error vs. strict Boykin regime; foundational on reliance on record)