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North Carolina v. Alford

Supreme Court of the United States · 1970 · Criminal Procedure

Criminal Procedureguilty pleaAlford pleamaintain innocencevoluntarinessguilty pleaAlford pleavoluntary and intelligent choice

Facts

Alford was indicted in North Carolina for first-degree murder, a capital offense. His appointed counsel investigated the witnesses Alford identified, but their statements strongly indicated guilt and did not support his claim of innocence; counsel therefore recommended pleading guilty to a reduced charge of second-degree murder, which the prosecutor agreed to accept. At the plea proceeding, the trial court heard sworn testimony summarizing the State's evidence that Alford had taken his gun, stated his intent to kill the victim, and later said he had done so. Alford testified that he had not committed the murder but was pleading guilty because he faced the death penalty if he went to trial, and the court accepted the plea and sentenced him to 30 years.

Issue

Whether the Constitution forbids acceptance of a guilty plea when the defendant simultaneously maintains his innocence but voluntarily chooses to plead guilty to avoid a possible death sentence. Also, whether a plea is rendered involuntary merely because its principal motivation is the defendant's desire to avoid the death penalty.

Rule

The constitutional standard for a guilty plea is whether it represents a voluntary and intelligent choice among the alternative courses of action open to the defendant. An express admission of guilt is not a constitutional prerequisite to imposition of criminal punishment; a court may accept a guilty plea accompanied by protestations of innocence when the defendant clearly wishes to plead guilty and the record contains strong evidence of actual guilt sufficient to provide a factual basis for the plea.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Daniel Ruiz is charged with aggravated homicide, which exposes him to a possible death sentence under state law. After reviewing witness statements, ballistics reports, and Daniel's own incriminating remarks, his lawyer advises him to plead guilty to a reduced noncapital homicide charge; at the plea hearing Daniel says, "I didn't do it, but I want this plea because I could lose at trial," and the judge hears a detailed proffer showing strong evidence of guilt.

Under the majority's constitutional rule, is Daniel's plea valid?

Explanation. The majority held that an express admission of guilt is not a constitutional prerequisite to a valid guilty plea. A court may accept a guilty plea accompanied by protestations of innocence when the defendant clearly wishes to plead guilty, the choice is voluntary and intelligent, and the record contains strong evidence of actual guilt providing a factual basis for the plea.