Corbitt v. New Jersey

Under New Jersey law, guilty pleas to murder charges were forbidden. Juries were required to decide whether the defendant was guilty and, if so, whether the offense was first or second degree murder. First degree murder carried a mandatory sentence of life imprisonment, and second degree murder carried a sentence of thirty years. Pleas of non vult or nolo contendere, however, were allowed in New Jersey. Defendants who pled non vult were sentenced to life imprisonment or thirty years, subject to the sentencing judge’s discretion and without the need for a findings of first versus second degree murder. Defendant pleaded not guilty to murder and was subsequently found guilty of first degree murder by a jury. Defendant challenged his conviction, arguing that the New Jersey law was an unconstitutional burden on his right to a jury trial. The Supreme Court rejected this argument, stating that not every burden on the exercise of a constitutional right, and not every pressure to waive that right, is invalid. The Court stated there is no per se rule against encouraging guilty pleas and that states may obtain guilty pleas by offering substantial benefits to defendants in return for the plea. The court also noted the states’ interest in encouraging the entry of guilty pleas and in facilitating plea bargaining.

“The cases in this Court since Jackson have clearly established that not every burden on the exercise of a constitutional right, and not every pressure or encouragement to waive such a right, is invalid. Specifically, there is no per se rule against encouraging guilty pleas. We have squarely held that a State may encourage a guilty plea by offering substantial benefits in return for the plea.” p.218-19