North Carolina v. Alford
| North Carolina v. Alford | |
|---|---|
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| Argued November 17, 1969 Reargued October 14, 1970 Decided November 23, 1970 |
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| Full case name | North Carolina v. Alford |
| Citations | 400 U.S. 25 (more)
91 S. Ct. 160; 27 L. Ed. 2d 162
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| Argument | Oral argument |
| Prior history | Appeal from the United States Court of Appeals for the Fourth Circuit |
| Holding | |
| There are no constitutional barriers in place to prevent a judge from accepting a guilty plea from a defendant who wants to plead guilty while still protesting his innocence. | |
| Court membership | |
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| Case opinions | |
| Majority | White, joined by Burger, Harlan, Stewart, Blackmun |
| Concurrence | Black |
| Dissent | Brennan, joined by Douglas, Marshall |
North Carolina v. Alford, 400 U.S. 25 (1970), was a case in which the Supreme Court of the United States affirmed that there are no constitutional barriers in place to prevent a judge from accepting a guilty plea from a defendant who wants to plead guilty while still protesting his innocence. This type of plea has become known as an Alford plea, differing slightly from the nolo contendere plea in which the defendant agrees to being sentenced for the crime, but does not admit guilt. Alford died in prison in 1975.
Henry Alford was a black man in the South at the height of the civil rights movement. He had visited a prostitute at a bar and allegedly got into a fight with Nathaniel Young. Young was later killed from a shotgun blast. Henry Alford was indicted for first-degree murder in North Carolina in December 1963. His attorney, just a few years out of law school, interviewed several witnesses and was convinced of Alford's guilt. Despite Alford’s claims of innocence and no eyewitness to the actual crime, witnesses saw him retrieve his gun, shortly before the murder, state he was going to kill the victim, and then upon returning home, stated that he had carried out the act. Alford also had a lengthy criminal history, including a prior conviction for murder. The attorney believed that Alford would probably be convicted in a trial, and thus recommended Alford plead guilty to the lesser charge of second-degree murder in order to avoid the death penalty. Ultimately, however, the decision was up to Alford. Before the plea was entered, the court heard sworn testimony from three witnesses. There were no eyewitnesses to the murder, but witnesses swore that Alford had taken his gun from his house and declared he was going to kill the victim, and upon returning, stated that he had killed the victim. Alford pleaded guilty to second-degree murder but declared to the court that he was in fact innocent, and was pleading guilty only to avoid the death penalty, which might have been applied had he been convicted of first-degree murder.
The judge sentenced Alford to the maximum second-degree murder penalty of 30 years in prison. Alford appealed on the constitutional ground that his plea was "the product of fear and coercion", in violation of his constitutional rights. A federal appeals court ruled that the plea was involuntary because it was motivated by fear of the death sentence, and the court should have rejected the guilty plea. The federal appeals court vacated the sentence of the lower court.
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