North Carolina v. Alford Case Brief Summary | Law Case Explained

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North Carolina v. Alford | 400 U.S. 25 (1970)

At an arraignment, a criminal defendant may plead guilty, not guilty, or nolo contendere, or no contest, where the defendant neither admits nor denies the charges.  When a defendant pleads guilty, the Fifth Amendment Due Process Clause requires the plea to be knowing, intelligent, and voluntary.  In the 1970 case North Carolina versus Alford, the United States Supreme Court considered whether a guilty plea is valid if the defendant maintains his or her innocence.

On December 2nd, 1963, Henry Alford was indicted in North Carolina for first-degree murder. At the time, North Carolina law authorized life imprisonment for a guilty plea to first-degree murder and the death penalty upon a conviction following a jury trial. In addition, North Carolina law authorized two to thirty years imprisonment for a second-degree murder charge.

The court appointed Alford an attorney, who, after questioning witnesses, recommended that Alford plead guilty. Further, the prosecutor in Alford’s case offered him a plea bargain where the state would drop the first-degree murder charge to second-degree murder if Alford plead guilty.

On December 10th, 1963, Alford accepted the deal and plead guilty to second-degree murder. However, before the plea was accepted by the court, the court heard testimony of the state’s case. After the presentation of the state’s case, Alford took the stand and testified, quote, “I pleaded guilty on second-degree murder because they said there is too much evidence, but I ain’t shot no man, but I take the fault for the other man,” unquote.  Additionally, after being asked if he still wanted to plead guilty, Alford testified, quote, “Yes, sir. . . . I’m not guilty but I plead guilty,” unquote.   The court then accepted the plea and sentenced Alford to thirty years’ imprisonment.

Subsequently, Alford sought post-conviction relief, which the North Carolina Supreme Court denied. Alford then filed a petition for writ of habeas corpus with the federal district court, which was denied. Alford appealed to the Fourth Circuit, which reversed the conviction and remanded the case. North Carolina appealed to the United States Supreme Court.

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