Michael Lejeune pleaded guilty to murder during his second jury trial and received life without parole. In habeas proceedings, he alleged that the plea was invalid because he had not been advised that he could not be compelled to testify against himself at trial. The habeas court denied relief, relying on earlier proceedings, Lejeune’s decision to testify at his first trial, and attorney testimony that it understood as showing an adequate awareness of his Boykin rights. The Supreme Court of Georgia held that those findings were unsupported or clearly erroneous, but it did not decide whether Lejeune ultimately proved a constitutional violation. The Court overruled Purvis v. Connell and its progeny, holding that the habeas petitioner—not the State—bears the burden of overcoming the presumption that a final conviction is regular and valid. It reasoned that Boykin governs direct review, while habeas is a collateral attack, and that Parke v. Raley rejects importing a presumption of invalidity into that setting. Because both parties and the habeas court had applied the wrong burden, the Court vacated the judgment and remanded for a new evidentiary hearing. Three justices dissented, arguing that Georgia precedent properly placed the burden on the State and that the existing record already showed a Boykin violation.