In North Carolina v. Alford (1970) the Supreme Court ruled that there are no constitutional barriers to bar a judge from accepting a guilty plea from a defendant who wants to plead guilty, while still protesting his innocence, under duress, as a detainee status. The plaintiff was a 53 year old African-American man named Henry Alford, who resided in Winston-Salem, North Carolina and had been convicted of murder and armed robbery. On November 22, 1963, while the nation's attention was drawn to a different, more high profile homicide case, Alford and a white female rented a room together at a "party house" in town and got into a fight with Nathaniel Young, its black proprietor. Young was killed that evening with a shotgun blast. Although Alford had not actually been seen shooting him, he was charged with 1st degree murder and the state argued that there was ample circumstantial evidence to prove his guilt. Further, Alford had a lengthy criminal history including a prior murder conviction. His public defender believed he didn't stand much chance of acquittal, so he urged him to plead guilty to 2nd degree murder.Alford did just that, but insisted it was only to avoid the death penalty and he was innocent of the crime he was being accused of. He was sentenced to up to 30 years in prison and immediately appealed on the grounds that his 5th Amendment rights had been violated. The 4th Circuit Court of Appeals ruled that the plea was involuntary and obtained under duress, and the court should have rejected the guilty plea.
The case was appealed to the Supreme Court, which ruled 6-3 that the trial judge in the case could accept a guilty plea even if the defendant believed himself innocent and there was nothing to prevent him from doing so. Justice White wrote the majority opinion and said that the Court had agreed to take on the case on the grounds that some states allowed conviction for a crime where guilt was demonstrated, including via a guilty plea that included an actual admission of guilt, but others permitted a defendant to plead guilty for a lesser sentence in a case where he clearly stood no chance of acquittal. White wrote that a court can accept any plea a defendant enters as long as his attorney is present, the plea is intelligently chosen, and there is ample evidence of his guilt. Since the difference between the plea bargain and being found guilty by a jury could be the electric chair, it might be the best option he could go for.Justice Brennan dissented. He argued that capital punishment in of itself violated the 8th Amendment and that Alford was compelled to plead guilty lest he risk the death penalty. The plea, said Brennan, should have been vacated and the case re-tried as it was obtained under duress.Henry Alford ended up serving 11 years for his crime and was paroled in 1974. He did not enjoy his freedom for very long--on June 27, 1975, he was struck by two vehicles and killed while attempting to cross a section of I-40 outside Winston-Salem.
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