Case title: North Carolina V. Alford
Citation: 400 U.S. 25
Year Decided: 1970
Henry Alford was arrested by the police for the murder of a bar patron. Alford and the bar patron entered into a fight where Alford left the bar and went home. Later the bar patron was found shot and killed although no one witnessed the shootings. However, Alford told others that he went home and took the gun and that he was going to kill the patron. Later he returned home and told them that he was through with the killing of the patron. In the courts he pleaded guilty but his reason for this he claimed he wanted to acquire a second-degree judgment and avoid a death sentence. After several appeals, the court of appeal granted him his wish and ruled that the use of a death sentence to convince a suspect to plead guilty violated Alford’s due process rights.
Did Alford’s plea violate his Fifth Amendment rights when he pleaded guilty to a murder charge to avoid the death penalty while proclaiming his innocence and get a second-degree murder conviction which warranted for a 30-year jail term? Yes.
Alford continued to assert that his pleas were out of fear and coercion and wanted to avoid a death penalty. He also claimed that this denied him his Fifth Amendment due process where it requires the suspect the right to a hearing process regardless of whether he pleaded guilty or not. Alford also argued that his attorney who was still a junior in matters law was not familiar with the law and in a way convinced him that it was wise to plead guilty to face a lesser charge. The government is prohibited from taking a person’s life or property without the following of the due process which is the right of a fair hearing. The Supreme Court began a review of the guilty plea right where it stated that it must be voluntary and intelligent. It refers to a case study of the U.S vs. Jackson which had ruled that if the state is found to have used the death penalty to coarse a suspect, there is a possibility of the ruling to be overturned. The court then tried to analyze whether the pleas of Alford were involuntary or was because of a lack of intelligence. The concluded that based on the factual evidence that was presented with the pleas that Alford was making, they had no other option than to enter a re-trial and accept his appeal.
According to the case, the holding was that there are no barriers from the constitution that prevents a judge from accepting the guilty pleas from a defendant. If the defendant is truthfully or willingly ready to plead guilty while still proving his innocence, then they are allowed to do so. This will be then considered under extreme duress and would be convicted as other detainees who have pleaded not guilty.
This case was significant to the extent that the situation whereby a suspect decides to plead guilty while still protecting their innocence is referred to as the Alford pleas. This case study brought another dimension in the judicial system whereby suspects who plead guilty out of the feat of facing the death sentence are considered and that their verdict can be overruled in case they decide to appeal. From Alford’s case any similar case that came afterward the judge had first to determine whether the plea was entered to lack of intelligence or it is involuntary due to fear of harsh punishment.
Clark, W., Saunders, W. L., & Weeks, S. B. (Eds.). (1909). The State Records of North Carolina (Vol. 27). PM Hale.
North Carolina v. Alford, 400 U.S. 25, 91 S. Ct. 160, 27 L. Ed. 2d 162 (1970).