North Carolina v. Alford
Citation: 400 U.S. 25 (1970)
Facts
Henry Alford was charged with first-degree murder, which carried the death penalty. Facing strong evidence of guilt, Alford’s attorney advised him to plead guilty to second-degree murder. Alford agreed but maintained throughout the plea colloquy that he was innocent, saying he was pleading guilty only to avoid the death penalty. The trial court accepted the plea over his protestations of innocence.
Issue
Whether the Constitution permits a court to accept a guilty plea from a defendant who simultaneously maintains his innocence, when the plea is voluntarily made and supported by a strong factual basis.
Holding
The Supreme Court held that a guilty plea accompanied by a claim of innocence does not violate the Constitution, so long as the plea is voluntary and intelligent and there is a strong factual basis for it in the record.
Rule
A court may constitutionally accept a guilty plea — now called an Alford plea — from a defendant who maintains innocence, provided the defendant voluntarily chooses the plea as a rational decision and the record contains strong evidence of actual guilt.
Significance
Alford recognized a distinct category of guilty plea used when defendants want the benefit of a plea bargain without admitting wrongdoing. It is widely debated whether Alford pleas serve justice and whether they are truly “voluntary” when offered to avoid extreme sentences. Some states do not permit Alford pleas.