Law School Case Brief
North Carolina v. Alford - 400 U.S. 25, 91 S. Ct. 160 (1970)
The standard for determining the validity of guilty pleas is whether a plea represents a voluntary and intelligent choice among the alternative courses of action open to a defendant.
Defendant Alford was indicted for first-degree murder. At that time, North Carolina law provided for the penalty of life imprisonment when a plea of guilty was accepted to a first-degree murder charge; for the death penalty following a jury verdict of guilty, unless the jury recommended life imprisonment; and for a penalty of 2 to 30 years' imprisonment for second-degree murder. Alford's attorney, in the face of strong evidence of guilt, recommended a guilty plea, but left the decision to Alford. The prosecutor agreed to accept a plea of guilty to second-degree murder. The trial court heard damaging evidence from certain witnesses before accepting a plea. Alford pleaded guilty, although disclaiming guilt, because of the threat of the death penalty, and was sentenced to 30 years' imprisonment. The court of appeals, on an appeal from a denial of a writ of habeas corpus, found that Alford's guilty plea was involuntary because it was motivated principally by fear of the death penalty.
Did the court of appeals err in holding that Alford's guilty plea was involuntary because it was motivated principally by fear of the death penalty?
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.
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