Is a guilty plea by a court or a confession by law enforcement officers obtained without the presence of any judicial officer or counsel invalid?

No analogy exists between the taking of a guilty plea by a court and the extraction of "cooperation" or a confession by law enforcement officers, without the presence of any judicial officer and without the presence of counsel. As Mr. Justice White said in Brady: "That a guilty plea is a grave and solemn act to be accepted only with care and discernment has long been recognized. Central to the plea and the foundation for entering judgment against the defendant is the defendant's admission in open court that he committed the acts charged in the indictment." (397 U.S. at 748, 90 S.Ct. at 1468.) "Since Gideon v. Wainwright, 372 U.S. 335 (83 S.Ct. 792, 9 L.Ed.2d 799) (1963), it has been clear that a guilty plea to a felony charge without counsel and without a waiver of counsel is invalid. (Citations omitted.)" (397 U.S. at 748-49, n. 6, 90 S.Ct. at 1469.)