Parker v. North Carolina

Fifteen-year-old African-American defendant was arrested after entering the yard where a burglary and rape had been committed. Defendant almost immediately confessed to the crimes. Faced with the death penalty if a jury found him guilty, defendant pleaded guilty and received a mandatory sentence of life imprisonment. After sentencing, defendant filed a petition under the North Carolina Post-Conviction Hearing Act claiming that his guilty plea was the product of a coerced confession and that the indictment was invalid because members of his race had been systematically excluded from the grand jury. The Court affirmed his conviction. Regarding defendant’s argument that his plea was invalid because it was induced by a fear of the jury’s potential sentence, the Court referred to the Brady decision and stated, “[A]n otherwise valid plea is not involuntary because induced by the defendant’s desire to limit the possible maximum penalty to less than that authorized if there is a jury trial.” Regarding the defendant’s argument that his confession was coerced and impermissibly influenced his decision to plead guilty, the Court held that it did not believe that any coercion related to the confession had the effect of making the plea of guilty over a month later involuntary. Finally, regarding the defendant’s argument that defendant’s counsel was wrong to believe the confession was admissible, which impacted the defendant’s assessment of whether to accept the plea or proceed to trial, the Court stated that any such error was not sufficient to render the plea unintelligent. Rather, the Court believed the advise the defendant received, which influenced his decision-making, was “well within the range of competence required of attorneys.”

“[A]n otherwise valid plea is not involuntary because induced by the defendant’s desire to limit the possible maximum penalty to less than that authorized if there is a jury trial. . . . Nor can we accept the claim that the plea was infirm because it was the product of a coerced confession.” p.794-95