North Carolina v. Alford

400 U.S. 25 (1970)

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Nature of the Case

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Facts

Alford (D) was indicted for first-degree murder. At that time in North Carolina (P), if one pled guilty to first-degree murder, the penalty was life imprisonment. If one was found guilty by a jury, the penalty was death. Second-degree murder carried a penalty from 2-30 years imprisonment. D, based on advice of counsel, pled guilty of second-degree murder. D's court-appointed attorney questioned all, but one of the various witnesses who D said would substantiate his claim of innocence. The witnesses, however, did not support D's story but gave statements that strongly indicated his guilt. Faced with strong evidence of guilt and no substantial evidentiary support for the claim of innocence, D's attorney recommended that he plead guilty, but left the ultimate decision to D. The trial court heard damaging evidence from witness testimony before accepting the plea. D's plea of guilty was offered, and the State's case was placed before the judge, Alford denied that he had committed the murder but reaffirmed his desire to plead guilty to avoid a possible death sentence and to limit the penalty to the 30-year maximum provided for second-degree murder. D was sentenced to 30 years in jail. D appealed. D claimed that his plea of guilty was invalid because it was the product of fear and coercion. The state court found that the plea was 'willingly, knowingly, and understandingly' made on the advice of competent counsel and in the face of a strong prosecution case. D petitioned for a writ of habeas corpus. The District Court and the Court of Appeals for the Fourth Circuit denied the writ on the basis of the state court's findings that D voluntarily and knowingly agreed to plead guilty. On appeal, a divided panel of the Court of Appeals for the Fourth Circuit reversed on the ground that D's guilty plea was made involuntarily. D's guilty plea was involuntary because its principal motivation was fear of the death penalty. The Supreme Court granted certiorari.