In the case of Margaret Bradshaw, Warden v. John David Stumpf, the U.S. Supreme Court was asked to consider whether a guilty plea can be considered valid if it is based on false information or misrepresentation by prosecutors. The case revolved around John David Stumpf who had pleaded guilty to murder charges in Ohio after being told that his accomplice would testify against him and confirm he was the shooter. However, during his accomplice's trial, evidence suggested otherwise which led Stumpf to appeal for post-conviction relief arguing that his plea was not knowingly and voluntarily made due to prosecutorial misconduct. The Sixth Circuit Court agreed with him but this decision was reversed by the Supreme Court which held that even if there were inconsistencies in prosecution’s theory between two separate trials regarding who fired fatal shots, it did not undermine defendant’s voluntary and intelligent plea agreement as long as substantial evidence supported each conviction independently.

In the dissenting opinion for Bradshaw v. Stumpf, Justice Souter disagreed with the majority's decision to remand the case back to lower courts for reconsideration of whether or not Stumpf’s guilty plea was knowing and voluntary. He argued that there was no reason to question its validity as it had been made intelligently and voluntarily in accordance with established legal standards. Furthermore, he contended that any inconsistencies between Stumpf’s confession and his co-defendant Wesley's testimony did not undermine this fact because they were irrelevant to his understanding of what he pleaded guilty to - aggravated murder during a robbery attempt. The dissent also expressed concern over potential implications on future cases where defendants plead guilty but later claim their pleas were unknowing or involuntary due to new evidence emerging after sentencing.