North Carolina v. Alford

Defendant was charged with first degree murder and faced either life in prison or the death penalty. Faced with what the Court described as “strong evidence of guilt and no substantial evidentiary support for the claim of innocence,” his attorney recommended that he plead guilty. Alford agreed to plead guilty to second-degree murder, which carried a maximum sentence of 30 years in prison. When pleading guilty, however, Alford stated that he was pleading guilty to avoid the death penalty and was not, in fact, guilty of the charges. After his statements, Alford was sentenced to 30 years in prison. Alford then sought post-conviction relief, claiming his plea was invalid and the result of coercion and fear. On appeal, the 4th Circuit found his plea involuntary. The Supreme Court determined the trial court had not erred in accepting the plea and stated that “[a]n 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.”

“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… Nor can we perceive any material difference between a plea that refuses to admit commission of the criminal act and a plea containing a protestation of innocence when, as in the instant case, a defendant intelligently concludes that his interests require entry of a guilty plea and the record before the judge contains strong evidence of actual guilt.” p.37