North Carolina V Alford, 400 U.S. 25 (1970)

Ana Correa

2/6/17                        

                                CASE BRIEF: North Carolina v. Alford

Case:                North Carolina v Alford, 400 U.S. 25 (1970)

Facts:                                 On December 2, 1963 Alford was convicted in a North Carolina court for first-degree murder. That charged carried the death penalty or a sentence of life imprisonment. Alford accepted to plead guilty in exchange for a second- degree murder, thus avoiding the death penalty. When Alford took the stand, he did not admit any guilt, and testified that he was innocent and plead guilty because he wanted to avoid the death penalty. Even though, he did not admit any guilt, the judge ensured that  Alford made the decision freely; as a result, the judge sentenced Alford to a maximum 30-year sentence. After the review, the Court of Appeals found that the plea was involuntary because its primary motivation was fear of the death penalty. Alford sought post-conviction-relief but it was unsuccessful, after attempting to obtain post- conviction relief, Alford petitioned for a writ of habeas corpus, and the U.S District Court for the Middle District of North Carolina denied his petition because Alford’s guilty plea was voluntarily. The U.S Court of Appeals reversed his case. The case was then appealed to the U.S Supreme Court.

Issue:                                 Is a guilty plea invalid where the defendant claims his innocence and testifies that the plea was only to avoid the death penalty? No.

Decision:         The judgement of the Court of Appeals was vacated and remanded for further proceeding.

Holding:                           The Supreme Court noted probable cause, and held that plea which represented voluntary and intelligent choice among alternatives available to defendant, especially where he was represented by competent counsel, was not compelled within the Fifth Amendment merely because plea was entered to avoid possibility of death penalty. The Supreme Court reasoned that in view of the strong factual basis for the plea demonstrated by the State and Alford’s clearly expressed desire to enter despite his belief in his innocence, the court   committed no constitutional error in accepting guilty plea despite defendant’s claim of innocence.