North Carolina v. Alford Case Brief

Why is the case important?

Appellee, facing the death penalty for first-degree murder, accepted a guilty-plea for murder, while maintaining his innocence. The Court of Appeals found that the plea was involuntary based on his fear of the death penalty.

Facts of the case

“North Carolina charged Henry Alford with first-degree murder. That charge carried a possible sentence of life imprisonment or the death penalty. Alford agreed to plead guilty in exchange for a second-degree murder conviction. When Alford took the stand, he testified that he was innocent and pled guilty to avoid the death penalty. The judge ensured that Alford made his decision freely after consulting counsel. Alford maintained his guilty plea, and after receiving evidence of Alford’s extensive criminal history, the judge sentenced Alford to the maximum 30-year sentence.After unsuccessfully attempting to obtain post-conviction relief, Alford petitioned for a writ of habeas corpus. The U.S. District Court for the Middle District of North Carolina denied relief on the grounds that Alford’s guilty plea was entirely voluntary. The U.S. Court of Appeals for the Fourth Circuit reversed, holding that the plea was involuntary because its primary motivation was the fear of death.”

Question

Whether a guilty plea made out of fear of the death penalty can be accepted when it is accompanied by protestations of innocence.

Answer

Yes. The Supreme Court of the United States first cited Brady v. United States, which held that a plea of guilty which would not have been entered except for the defendant’s desire to avoid a possible death penalty and to limit the maximum penalty to life imprisonment or a term of year was not for that reason compelled within the meaning of the Fifth Amendment. As this standard still applied, the Supreme Court held that, without more the Court of Appeals would be vacated and remanded. However, the additional fact that the appellee Alford entered his plea but accompanied it with the statement that he had not shot the victim led the Supreme Court to consider the matter further, as, generally, a judgment of conviction resting on a plea of guilty is justified by the defendant’s admission that he committed the crime charged against him and his consent that judgment be entered without a trial of any kind. The Supreme Court cited some precedence, but concluded that they we
re different as Alford had insisted on his innocence. The Supreme Court also noted the substantial evidence provided by witnesses which tended to demonstrate his guilt. The Supreme Court concluded that in view of the strong factual basis for the plea demonstrated by the State and Alford’s clearly expressed desire to enter it despite his professed belief in his innocence, there was no error in accepting the plea.

Conclusion

The Supreme Court of the United States held that the mere fact that Alford would not have pleaded guilty except for the opportunity to limit the possible penalty did not show that the plea did not result from a free and rational choice, especially where he was represented by competent counsel whose advice was that the plea would be to Alford’s advantage due to the great weight of the evidence against him. According to the Court, the standard for determining the validity of a guilty plea was whether it represented a voluntary and intelligent choice among the available alternatives. In view of the strong factual basis for the plea shown by the State and Alford’s clear desire to enter it despite his professed innocence, the trial judge did not commit constitutional error in accepting the plea.

  • Case Brief: 1970
  • Appellant: North Carolina
  • Appellee: Henry C. Alford
  • Decided by: Burger Court

Citation: 400 US 25 (1970)
Argued: Nov 17, 1969
ReArgued: Oct 14, 1970
Decided: Nov 23, 1970
Granted Apr 7, 1969