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

2012-08-10 16:38:50

When defendants in criminal cases enter pleas of guilty, they are generally doing so because they committed the crime with which they are charged. However, there are some circumstances under which a defendant might decide that it is in his best interest to enter a plea of guilty even if he has not committed a crime. In North Carolina v. Alford, the U.S. Supreme Court addressed the issue of whether a court could accept a guilty plea if the defendant claims that he did not commit the charged offense.

Henry C. Alford was charged with first-degree murder, a crime that carried a potential death sentence if convicted by a jury. The prosecutor agreed to accept a guilty plea to second-degree murder in the case, a charge that carried a possible sentence of two to thirty years’ imprisonment. Alford agreed to accept this plea offer because, although he claimed innocence, he feared that he would be convicted and sentenced to death if he took his case to trial. The trial court accepted the guilty plea, but the appellate court overturned Alford’s conviction. The U.S. Supreme Court agreed to hear the case and held that a defendant need not admit guilt to enter a plea of guilty in a criminal case, as long as the guilty plea represents a voluntary and intelligent choice among alternatives available to the defendant, and there are sufficient facts to support the conviction.


References and Further Reading

  • Cohen, Neil P., and Donald J. Hall. Criminal Procedure: The Post-Investigative Process, Cases and Materials. 2nd ed. New York: LEXIS Publishing, 2000.
  • Cook, Julian A., All Aboard! The Supreme Court, Guilty Pleas, and the Railroading of Criminal Defendants, University of Colorado Law Review 75 (2004): 863.

See also Guilty Plea