North Carolina v. Alford

In North Carolina v. Alford, 400 U.S. 25 (1970), a defendant indicted for the capital crime of first-degree murder pled guilty to a reduced charge of second-degree murder while simultaneously protesting his innocence. Alford, 400 U.S. at 28. The defendant wished to plead guilty to second degree murder in order to obtain life imprisonment in lieu of a sentence of death. The evidence of guilt was overwhelming. Nevertheless, he made a claim of innocence before entering his plea. His counsel had fully informed the defendant of his defenses and his constitutional rights. The defendant pled guilty and the court found that the plea was willingly, knowingly and understandingly made. On appeal, the defendant challenged the voluntariness of his plea on the grounds that it was the product of coercion and fear of the death penalty. Relying in part on the earlier case of Lynch v. Overholser (1962) 369 U.S. 705, 719, and the English common law, the court rejected the defendant's claim and held that an individual may waive trial and accept guilt without admitting guilt of the offense. The court said an express admission of guilt is not a constitutional prerequisite to the imposition of a criminal penalty. (North Carolina v. Alford, supra, at p. 37.) In reaching this decision, the court in Alford noted that pleas coupled with claims of innocence should not be accepted unless there is a factual basis for the plea and until the court taking the plea has inquired into and sought to resolve the conflict between the waiver of a trial and the claim of innocence. (Id. at p. 38, fn. 10.) The Alford court said: "Our holding does not mean that a trial judge must accept every constitutionally valid guilty plea merely because a defendant wishes so to plead. A criminal defendant does not have an absolute right under the Constitution to have his guilty plea accepted by the court, see Lynch v. Overholser, 369 U.S., at p. 719 (by implication), although the States may by statute or otherwise confer such a right. Likewise, the States may bar their courts from accepting guilty pleas from any defendants who assert their innocence. Cf. Fed. Rule Crim. Proc. 11, which gives a trial judge discretion to 'refuse to accept a plea of guilty . . . .' We need not now delineate the scope of that discretion." (North Carolina v. Alford, supra, 400 U.S. at p. 38, fn. 11.) Before the plea was formally accepted by the trial court, and after the state of North Carolina had presented its case, Alford took the stand and testified that he did not commit the murder, but rather, that he was pleading guilty because he faced the threat of the death penalty if he did not do so. Id. When queried, Alford acknowledged on the record that his counsel informed him of the difference between second-degree and first degree murder and of his rights if he chose to go to trial. Id. at 28-29. "The trial court then asked Alford if, in light of his denial of guilt, he still desired to plead guilty to the reduced charge." Id. at 29. He said yes. Id. The Court held that there is no constitutional error in accepting a guilty plea despite a defendant's claim of innocence "where strong evidence of actual guilt substantially negated defendant's claim of innocence and provided a strong factual basis for the guilty plea, and the state had a strong case of first-degree murder, so that defendant, advised by competent counsel, intelligently concluded that he should plead guilty to second-degree murder rather than be tried for the higher charge." Id. at 25.