Summary of North Carolina v. Alford
Citation: 400 U.S. 25 (1970)
Relevant Facts: Henry Alford was indicted for first-degree murder in North Carolina. After conferring with his attorney, the attorney interviewed witnesses and conducted an investigation, concluding that Alford would most likely be convicted at trial and face the death penalty. He convinced Alford to plead guilty to second-degree murder and avoid the possibility of a death sentence. Alford reluctantly agreed to his attorney’s advice, but during the course of pleading guilty professed his innocence and explained that he was only pleading guilty to avoid the possibility of the death penalty. A North Carolina judge accepted Alford’s plea and sentenced him to thirty years imprisonment, the maximum allowed by statute. Alford appealed, claiming that his plea had been coerced by the threat of the death penalty.
Issue: Does the threat of the death penalty render a plea to a lesser charge, expressly for the purpose of avoiding the death penalty, a coerced plea? Does the Constitution prohibit pleas in which defendants accept punishment for the crimes charged but maintain their innocence?
Holding: No, the threat of the death penalty does not coerce a defendant into pleading to a lesser charge, and states have the authority to accept such pleas. No, there is no constitutional bar to accepting a guilty plea by a defendant even where he does not admit complicity in the crime charged.
Reasoning: Justice White, writing for the majority, explained that the death penalty had no effect on the traditional standard for evaluated a plea for coercion. Defendants that make a free and voluntary choice to plead guilty, adequately assisted by counsel, may choose to do so even where they maintain their innocence. Desire to avoid the death penalty alone is insufficient to make an otherwise valid plea coerced within the meaning of the Due Process Clause. Noting the differences across jurisdictions regarding accepting guilty pleas from defendants unwilling to admit their guilt, the Court concluded that the appropriate inquiry was whether the judge accepting the plea had sufficient evidence of guilt, not whether the defendant admitted his guilt. Justice White also explained that there was no basis for distinguishing cases where a defendant professes his innocence from cases in which a defendant pleads guilty but refuses to admit his guilt. States are not required to proceed to trial when defendants voluntarily plead to lesser included charges while maintaining their innocence. Finally, the Court explained that defendants may well choose to plead guilty even where they are not, in fact, guilty based on an evaluation of the strength of the case against them. When, as here, the defendant has competent counsel and makes the knowing, voluntary choice to enter a plea, the outcome remains the same even when he continues to profess innocence.
Dissent: Justice Black concurred in the decision, pointed out that he agreed with the majority but would have preferred to revisit other portions of the Court’s death penalty jurisprudence. Justice Brennan, joined by Justices Marshall and Douglas, dissented. He argued that the threat the death penalty, like any other type of death threat, makes it difficult to accept that a plea is indeed voluntary and without coercion, in particular when the defendant maintains his innocence. Justice Brennan concluded that the threat of death here was sufficient to put the defendant under duress, and as such render his plea involuntary. Citing examples for numerous jurisdictions in which courts refused to accept pleas accompanied by professions of innocence, Justice Brennan concluded that the Court should have sided with those jurisdictions as a means of protecting defendants from being forced into accepting plea agreements under threat of more severe punishment.
Conclusion: States may allow defendants to plead guilty to crimes while maintaining their innocence without running afoul of due process protections. Courts should focus on evidence of guilt in accepting guilty pleas, not the willingness of the defendant to personally admit his guilt.