North Carolina v. Alford case brief summary
400 U.S. 25 (1970)
CASE FACTS
A judgment reversing the denial of appellee's petition for a writ of habeas corpus on the ground that a guilty plea in a murder case was made involuntarily because its principal motivation was fear of the death penalty was vacated and the case was remanded. Appellee testified in state court that he did not commit the murder but chose to plead guilty to avoid the threat of the death penalty.
DISCUSSION
CONCLUSION
A judgment reversing the denial of appellee's petition for a writ of habeas corpus on the ground that appellee's guilty plea in a murder case was made involuntarily was vacated and the case was remanded for further proceedings where the fact that appellee would not have pleaded guilty except for the opportunity to limit the possible penalty did not necessarily show that the plea was not the product of a free and rational choice.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
400 U.S. 25 (1970)
CASE SYNOPSIS
Appellant, the State of North Carolina,
sought review of a judgment from the United States Court of Appeals
for the Fourth Circuit that reversed the denial of appellee's
petition for a writ of habeas corpus on the ground that appellee's
guilty plea in a murder case was made involuntarily because his
principal motivation was fear of the death penalty.CASE FACTS
A judgment reversing the denial of appellee's petition for a writ of habeas corpus on the ground that a guilty plea in a murder case was made involuntarily because its principal motivation was fear of the death penalty was vacated and the case was remanded. Appellee testified in state court that he did not commit the murder but chose to plead guilty to avoid the threat of the death penalty.
DISCUSSION
- The Supreme Court held that the mere fact that appellee would not have pleaded guilty except for the opportunity to limit the possible penalty did not show that the plea did not result from a free and rational choice, especially where appellee was represented by competent counsel whose advice was that the plea would be to appellee's advantage due to the great weight of the evidence against him.
- According to the Court, the standard for determining the validity of a guilty plea was whether it represented a voluntary and intelligent choice among the available alternatives.
- In view of the strong factual basis for the plea shown by the State and appellee's clear desire to enter it despite his professed innocence, the trial judge did not commit constitutional error in accepting the plea.
CONCLUSION
A judgment reversing the denial of appellee's petition for a writ of habeas corpus on the ground that appellee's guilty plea in a murder case was made involuntarily was vacated and the case was remanded for further proceedings where the fact that appellee would not have pleaded guilty except for the opportunity to limit the possible penalty did not necessarily show that the plea was not the product of a free and rational choice.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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