North Carolina v. Alford

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North Carolina v. Alford
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued November 17, 1969
Reargued October 16, 1970
Decided November 23, 1970
Full case nameNorth Carolina v. Alford
Citations400 U.S. 25 ( more )
91 S. Ct. 160; 27 L. Ed. 2d 162
Argument Oral argument
Case history
PriorAlford v. North Carolina, 405 F.2d 340 (4th Cir. 1968), probable jurisdiction noted, 394 U.S. 956(1969).
Holding
There are no constitutional barriers in place to prevent a judge from accepting a guilty plea from a defendant who wants to plead guilty while still protesting his innocence under extreme duress in a detainee status.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
Hugo Black  · William O. Douglas
John M. Harlan II  · William J. Brennan Jr.
Potter Stewart  · Byron White
Thurgood Marshall  · Harry Blackmun
Case opinions
MajorityWhite, joined by Burger, Harlan, Stewart, Blackmun
ConcurrenceBlack
DissentBrennan, joined by Douglas, Marshall

North Carolina v. Alford, 400 U.S. 25 (1970), [1] was a case in which the Supreme Court of the United States affirmed that there are no constitutional barriers in place to prevent a judge from accepting a guilty plea from a defendant who wants to plead guilty, while still protesting his innocence, under duress, as a detainee status. [2] [3] This type of plea has become known as an Alford plea, differing slightly from the nolo contendere plea in which the defendant agrees to being sentenced for the crime, but does not admit guilt. [2] Alford died in prison in 1975. [4]

Contents

Case

Trial and appeals

Henry Alford was a black man in the South, at the height of the civil rights movement, who had previously been convicted of murder and armed robbery. On November 22, 1963, Alford and a white woman companion rented a room at a “party house” in Winston-Salem, North Carolina and allegedly got into a fight with its proprietor, Nathaniel Young, who was also black. Later, that same evening, an assailant murdered Young with a shotgun. [5] Henry Alford was indicted for first-degree murder in North Carolina, in December 1963. [3] His attorney, Fred Crumpler, [6] with six years experience, interviewed several witnesses and was convinced of Alford's guilt. Despite Alford's claims of innocence and the lack of eyewitnesses to the crime itself, witnesses observed Alford retrieve his gun shortly before the murder, heard him state he was going to kill the victim, and then state that he had done so, once he returned home. Alford also had a lengthy criminal history, including a prior conviction for murder. The attorney believed that Alford would probably be convicted at trial, [3] and thus, he recommended Alford plead guilty to the lesser charge of second-degree murder, in order to avoid the death penalty. Ultimately, however, the decision was up to Alford. [3] Before the plea was entered, the court heard sworn testimony from three witnesses. [3] Alford pleaded guilty to second-degree murder but declared to the court that he was, in fact, innocent, and he was pleading guilty only to avoid the death penalty, which might have been applied, had he been convicted of first-degree murder. [2]

The judge sentenced Alford to the maximum second-degree murder penalty of 30 years in prison. [2] Alford appealed, on the constitutional ground that his plea was "the product of fear and coercion,” in violation of his constitutional rights. Ultimately, the United States Court of Appeals for the Fourth Circuit ruled that the plea was involuntary, because it was motivated by fear of the death sentence, and the court should have rejected the guilty plea. [2] The federal appeals court vacated the sentence of a United States district court. [2]

Supreme Court ruling

Majority

Justice Byron White wrote that the Court had accepted the case for review, because some states authorized conviction only for a crime “where guilt is shown,” including by means of a guilty plea that included an actual admission of guilt, but “others have concluded that they should not ‘force any defense on a defendant in a criminal case,’ particularly when advancement of the defense might ‘end in disaster,” and therefore would accept a guilty plea in Alford's circumstances. [3]

White wrote that courts may accept whatever plea a defendant chooses to enter, as long as the defendant is competently represented by counsel; the plea is intelligently chosen; and “the record before the judge contains strong evidence of actual guilt.” [3] Faced with “grim alternatives,” the defendant's best choice of action may be to plead guilty to the crime, White wrote, and the courts must accept the defendant's choice made in his own interests. [3]

Dissent

In the dissent, Justice William Brennan stated that capital punishment in the United States was unconstitutional, and wrote that the actual effect of this unconstitutional threat to Alford was to induce a guilty plea. [3] He concluded the plea should have been vacated and Alford should have been retried, writing: "the facts set out in the majority opinion demonstrate that Alford was 'so gripped by fear of the death penalty' that his decision to plead guilty was not voluntary but was "the product of duress as much so as choice reflecting physical constraint." [3]

Commentary

Stephanos Bibas (who would be appointed as a federal judge by President Donald Trump in 2017) has spoken out against the Alford plea on the moral ground that it undermines public confidence in the accuracy and fairness of the criminal justice system, sending some people to jail who profess innocence; and that it dodges the "morality play" aspect of a criminal trial, in which the community sees that the guilty are punished. [7]

See also

Related Research Articles

<span class="mw-page-title-main">Arraignment</span> Formal reading of the offence to a criminal defendant

Arraignment is a formal reading of a criminal charging document in the presence of the defendant, to inform them of the criminal charges against them. In response to arraignment, in some jurisdictions, the accused is expected to enter a plea; in other jurisdictions, no plea is required. Acceptable pleas vary among jurisdictions, but they generally include guilty, not guilty, and the peremptory pleas setting out reasons why a trial cannot proceed. Pleas of nolo contendere and the Alford plea are allowed in some circumstances.

In United States law, an Alford plea, also called a Kennedy plea in West Virginia, an Alford guilty plea, and the Alford doctrine, is a guilty plea in criminal court, whereby a defendant in a criminal case does not admit to the criminal act and asserts innocence, but accepts imposition of a sentence. This plea is allowed even if the evidence to be presented by the prosecution would be likely to persuade a judge or jury to find the defendant guilty beyond a reasonable doubt. This can be caused by circumstantial evidence and testimony favoring the prosecution, and difficulty finding evidence and witnesses that would aid the defense.

Nolo contendere is a type of legal plea used in some jurisdictions in the United States. It is also referred to as a plea of no contest or no defense. It is a plea where the defendant neither admits nor disputes a charge, serving as an alternative to a pleading of guilty or not guilty. A no-contest plea means that defendants refuse to admit guilt but accept punishment as if guilty, and is often offered as a part of a plea bargain.

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In law, a plea is a defendant's response to a criminal charge. A defendant may plead guilty or not guilty. Depending on jurisdiction, additional pleas may be available, including nolo contendere, no case to answer, or an Alford plea.

<span class="mw-page-title-main">Acquittal</span> The legal result of a verdict of not guilty

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This adjustment is not intended to apply to a defendant who puts the government to its burden of proof at trial by denying the essential factual elements of guilt, is convicted, and only then admits guilt and expresses remorse. Conviction by trial, however, does not automatically preclude a defendant from consideration for such a reduction. In rare situations a defendant may clearly demonstrate an acceptance of responsibility for his criminal conduct even though he exercises his constitutional right to a trial. This may occur, for example, where a defendant goes to trial to assert and preserve issues that do not relate to factual guilt. In each such instance, however, a determination that a defendant has accepted responsibility will be based primarily upon pre-trial statements and conduct.

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Brady v. United States, 397 U.S. 742 (1970), was a United States Supreme Court case in which the Court refused to hold that large sentencing discounts and threats of the death penalty are sufficient evidence of coercion.

In United States criminal law, a factual basis is a statement of the facts detailing an individual crime and its particulars, stipulated to by the prosecution and the defense, which forms a basis by which a judge can accept a guilty plea from the defendant.

Lafler v. Cooper, 566 U.S. 156 (2012), was a United States Supreme Court case in which the Court clarified the Sixth Amendment standard for reversing convictions due to ineffective assistance of counsel during plea bargaining. The Court ruled that when a lawyer's ineffective assistance leads to the rejection of a plea agreement, a defendant is entitled to relief if the outcome of the plea process would have been different with competent advice. In such cases, the Court ruled that the Sixth Amendment requires the trial judge to exercise discretion to determine an appropriate remedy.

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References

  1. ↑ "U.S. Reports: North Carolina v. Alford, 400 U.S. 25 (1970)". Library of Congress . November 23, 1970. Retrieved June 30, 2024.
  2. 1 2 3 4 5 6 Champion, Dean J. (1998). Dictionary of American Criminal Justice: Key Terms and Major Supreme Court Cases . Routledge. p.  250. ISBN   1-57958-073-4.
  3. 1 2 3 4 5 6 7 8 9 10 Acker, James R.; David C. Brody (2004). Criminal Procedure: A Contemporary Perspective. Jones & Bartlett Publishers. pp. 485–488. ISBN   0-7637-3169-2.
  4. ↑ "David Hejmanowski: The lasting legacy of Henry Alford". The Delaware Gazette . July 1, 2016. Retrieved April 21, 2022.
  5. ↑ https://www.supremecourt.gov/pdfs/transcripts/1969/69-50_11-17-1969.pdf [ bare URL PDF ]
  6. ↑ "Obituary information for Fred G. Crumpler Jr".
  7. ↑ Bibas, Stephanos (2003). "Harmonizing Substantive Criminal Law Values and Criminal Procedure: The Case of Alford and Nolo Contendere Pleas". Cornell Law Review . 88 (6). doi:10.2139/ssrn.348681.

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