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North Carolina v. Alford: Difference between revisions
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|rule=[https://www.quimbee.com/keyterms/nolo-contendere ''Nolo Contendere''] = no contest with the effect of guilty plea | |rule=[https://www.quimbee.com/keyterms/nolo-contendere ''Nolo Contendere''] = no contest with the effect of guilty plea | ||
Alford plea = guilty plea while claiming innocence to accept a penalty that is less harsh | |||
|case_text_links={{Infobox Case Brief/Case Text Link | |case_text_links={{Infobox Case Brief/Case Text Link | ||
|link=https://www.quimbee.com/cases/north-carolina-v-alford | |link=https://www.quimbee.com/cases/north-carolina-v-alford |
Latest revision as of 10:57, December 28, 2023
North Carolina v. Alford | |
Court | Supreme Court of the United States |
---|---|
Citation | 400 U.S. 25 91 S.Ct. 160 27 L.Ed.2d 162 |
Date decided | November 23, 1970 |
Appealed from | North Carolina Supreme Court & 4th Circuit |
Facts
- On December 2nd 1963, Henry Alford was indicted in North Carolina for 1st-degree murder
- In the early 1960s, North Carolina law authorized
- life imprisonment for guilty plea to 1st degree murder &
- the death penalty conviction following a jury trial for 1st-degree murder
- North Carolina law authorized 2 to 30 years imprisonment for 2nd-degree murder
- The prosecutor in offered to reduce the 1st degree-murder charge to 2nd-degree murder if Alfred pled guilty
- On December 10th 1963, Alfred pled guilty to 2nd-degree murder
- Alfred announced, "I am not guilty, but I plead guilty."
Procedural History
The court sentenced Alfred to 30 years of imprisonment for 2nd-degree murder following his guilty plea.
North Carolina Supreme Court denied Alfred post-conviction relief.
Alfred's filing for a writ of habeas corpus with the federal district court was denied, too.
Alfred appealed to the 4th Circuit which reversed the conviction & remanded the case for a new trial.
North Carolina prosecutors appealed to SCOTUS.Issues
Can a guilty plea be accepted by a court when the defendant also maintains his or her innocence to the crime?
Holding
Yes. A guilty plea can be accepted even if the defendant maintains his or her innocence so long as the plea represents a voluntary & intelligent choice.
Judgment
vacated the 4th circuit & case remanded
Reasons
Byron White cited Brady v. United States (1970)
Rule
Nolo Contendere = no contest with the effect of guilty plea
Alford plea = guilty plea while claiming innocence to accept a penalty that is less harshResources