North Carolina v. Alford
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| 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
