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North Carolina v. Alford

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Bloomberg Law

Citation. 400 U.S. 25, 91 S. Ct. 160, 27 L. Ed. 2d 162, 1970 U.S.

Brief Fact Summary. Appellee, facing the death penalty for first-degree murder, accepted a guilty-plea for murder, while maintaining his innocence. The Court of Appeals found that the plea was involuntary based on his fear of the death penalty.

Synopsis of Rule of Law. “An individual accused of crime may voluntarily, knowingly, and understandingly consent to the imposition of a prison sentence even if he is unwilling or unable to admit his participation in the acts constituting the crime.”

Facts. Appellee Alford was indicted for first-degree murder, and faced the death penalty if convicted by a jury. Substantial evidence pointed to his guilt. He accepted a guilty plea for second-degree murder, thus avoiding the death penalty. He did not admit any guilt, but the court heard substantial eye-witness testimony. On review, the Court of Appeals found that the plea was involuntary because it was motivated by fear of the death penalty.

Issue. “[Whether a guilty plea [made out of fear of the death penalty] can be accepted when it is accompanied by protestations of innocence.”

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