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List of people who entered an Alford plea

January 01, 1970

The following is an incomplete list of notable individuals that have entered an Alford plea. An Alford plea (also referred to as Alford guilty plea[1][2][3] and Alford doctrine)[4][5][6] in the law of the United States is a guilty plea in criminal court,[7][8][9] where the defendant does not admit the act and asserts innocence.[10][11][12] Under the Alford plea the defendant admits that sufficient evidence exists with which the prosecution could likely convince a judge or jury to find the defendant guilty beyond a reasonable doubt.[4][13][14][15][16]

Background edit

Supreme Court case edit

 
Supreme Court Justice Byron White wrote the majority opinion

This form of plea is derived from the 1970 ruling by the Supreme Court of the United States, in the case North Carolina v. Alford.[17] Henry Alford of Forsyth County, North Carolina was indicted for first degree murder in 1963.[18][19] At the time under North Carolina law a conviction of first degree murder automatically brought with it the death penalty, unless the jury recommended otherwise, in which case the defendant would receive a mandatory life sentence.[20][21] Alford said he was innocent, but the prosecution had significant evidence to the contrary.[19] Witnesses stated Alford had said he wanted to kill the victim, then grabbed his gun and left his residence.[19] Witnesses said that Alford subsequently declared he had killed the victim.[19] His defense advised Alford to plead to the crime of second degree murder because of the belief that the strong evidence would lead to a conviction.[19] He pleaded guilty to second degree murder in 1963.[18] He did so in order to avoid a possible death sentence.[18] Alford maintained he was innocent of the crime itself, but feared going to trial because of the capital punishment associated with the charge of first degree murder.[22] He was given a sentence of thirty years in jail.[18]

Alford appealed, and argued that his conviction for second degree murder should be overturned because he said the plea was coercive in nature.[23] The matter came before the Supreme Court, and in its ruling the court said that the trial judge in Alford's criminal case was appropriate in having accepted the defendant's plea of guilty.[18] The Court said that the decision to plead guilty while maintaining his innocence was a reasonable choice for Alford to have made at the time.[23] Supreme Court Justice Byron White wrote the majority opinion.[18] The Supreme Court case was decided 5–3.[18] "[T]hat he would not have pleaded except for the opportunity to limit the possible penalty does not necessarily demonstrate that the plea of guilty was not the product of a free and rational choice", said the Supreme Court decision.[22] The Court ruled that a plea of guilty that was "a voluntary and intelligent choice among the alternative courses of action" was not a coercive decision.[21] Justice White wrote that, "Express admission of guilt is not constitutional requisite to imposition of criminal penalty."[20] In 1975, Alford died while in jail at the age of 57.[19]

Usage of plea edit

When a defendant indicates an intention to plead guilty by Alford plea, the judge asks two questions: "Do you now consider it to be in your best interest to plead guilty?" and "Do you understand that upon your 'Alford plea' you will be treated as being guilty whether or not you admit that you are in fact guilty?"[19] Prosecutors and defense lawyers characterize Alford pleas as a required method of lessening pressure of the nature of the justice process.[17] Both parties get to maneuver around not knowing what the outcome could be at trial, and are able to come to a resolution.[17] The Alford plea does not itself affect the sentencing process, and the convicted individual is sentenced just as if he had entered a normal guilty plea.[18][20] The defendant may be hurt at the sentencing process by having used an Alford plea, as the judge may see this as a sign that the defendant has not accepted responsibility for his actions.[24] Duke University law professor Robert P. Mosteller commented on this possible effect at sentencing, "They get you more harm than good."[24] Orange County, North Carolina District Attorney Jim Woodall said that the frequency of Alford pleas is higher with criminal cases involving a charge of a sexual offense, as the defendant does not wish to admit to their family and the public that they were responsible for the crime.[24] Psychologist Bob Carbo noted that sexual offenders undergoing treatment for their actions after being ordered to so under terms of their Alford plea cause problems because the first step in therapy is to take responsibility for committing the crime.[24] "We can't help this person if they're not willing to admit they did something", said Carbo.[24]

John Gulash, a lawyer on the Connecticut State Bar Association's criminal justice executive committee, acknowledged, "It's unfortunate, but it's a reality that you will receive, in most instances, a much more severe penalty if you lost after trial than if you pled before the trial."[17] Defendants gain the potential benefit of being able to tell possible employers after their conviction in a crime that they maintained their innocence and only pleaded guilty under the Alford doctrine because of the nature of the situation and the evidence presented.[17] Professor of law at Quinnipiac University and former federal prosecutor Jeffrey Meyer said of the Alford doctrine, "It's part of an idealist vision of a judicial system that it is for the adjudication of truth."[17] Meyer commented on what would happen were the Alford doctrine to become no longer applicable, "My suspicion is if the state could dispense with the Alford doctrine, over time, it probably wouldn't change very much the rate at which cases plead out. More than 95 percent of cases in federal court go by guilty plea. It's difficult to make the case that without the Alford doctrine, there would be an immense number of defendants who would end up going to trial."[17] Raleigh, North Carolina lawyer Wade Smith said that the frequency of application of the Alford plea is, "Fairly often. There are many times when people don't want to plead guilty, but then do, in fact, plead guilty."[18]

List edit

This is a dynamic list and may never be able to satisfy particular standards for completeness. You can help by adding missing items with reliable sources.

A edit

  • Raven Abaroa - The jury was deadlocked in Raven Abaroa's 2013 trial for the murder of his wife Janet. When the state of North Carolina offered him a deal shortly before his second trial was to begin, he took it, saying, "I didn't receive a fair trial the first time, and I don’t think I'll receive a fair trial the second time." Abaroa was sentenced to 95 to 123 months in prison for the crime of voluntary manslaughter, and ended up serving approximately 7 years.[25][26]
  • Henry Alford – indicted for first degree murder in 1963; maintained his innocence but pleaded guilty to second degree murder due to the significance of the evidence.[27] He pleaded guilty to second degree murder so as to avoid the death penalty.[23] Alford appealed, and the Supreme Court of the United States issued a ruling that trial courts are allowed to accept pleas of guilty from criminal defendants even if the defendants do not wish to admit to guilty, and wish to plead guilty in order to take advantage of a plea deal.[27] This type of plea described by the 1970 ruling of the Supreme Court became known as the Alford plea.[27]
  • John Dylan Adams - entered an Alford plea in the kidnapping, rape and killing of 20-year-old nursing student Holly Lynn Bobo. Adams is currently (April 2018) serving a 35-year sentence without parole in the Tennessee Department of Correction.[1]

B edit

  • Scott Bairstow – actor of Party of Five fame, entered Alford plea in 2003 to second-degree assault; was initially charged with second-degree child rape of 12-year-old girl.[28] He received a sentence of four months in jail for the assault.[29]
  • Jason Baldwin. Arkansas, 2011 One of the West Memphis Three.[30] Along with Echols and Misskelley, he was convicted of the 1993 murders of three 8-year-old boys in 1994. He was sentenced to life without parole. He entered the plea to get Echols off death row. He was sentenced to time served: 18 years and 78 days and released that same day.
  • James B. Black, former Speaker of the North Carolina House of Representatives, gave an Alford plea in 2007 on charges brought by the state of North Carolina of obstruction of justice and bribery.[24][31] Black was accused of bribing former state Representative Michael Decker $50,000 to switch his political allegiance, thereby keeping Black in power as co-Speaker of the House.[32]
  • Michael Bray – American anti-abortion activist; he was arrested by U.S. federal law enforcement from the ATF in connection with an anti-abortion bombing.[33] He entered an Alford plea in 1987 and received a prison sentence of six years.[34] He served just over forty-six months in a federal jail.[34]
  • Ted Brown – American and former collegiate and professional football player, played for the Minnesota Vikings.[35] After being charged with criminal sexual assault in an incident in Mille Lacs County, Minnesota, Brown entered an Alford plea on a lesser charge, and agreed to perform 100 hours of community service.[35] Mille Lacs County challenged the plea deal,[36] and in 2006 a ruling from the Minnesota Court of Appeals overturned it after the woman involved in the incident told prosecutors she did not approve of the deal.[37]

C edit

  • Kiari Cephus – rapper known as Offset; entered an Alford plea in December 2015 to felony battery and inciting a riot within a penal facility in exchange for dismissing criminal charges in relation to an April 2015 arrest at the Georgia Southern University for drug and firearm possession.[38]
  • Raymond Clark III, the perpetrator in the murder of Annie Le.
  • H. Brent Coles – former Mayor of Boise, Idaho; entered an Alford plea to two felony charges of presenting a fraudulent account or voucher and misuse of public money by officers.[39] The plea was made in accordance with a deal by the State Attorney General of Idaho.[39] Coles had resigned from his position as mayor amidst complaints filed against him by the State Attorney General's office.[40]

E edit

  • Damien Echols, Arkansas, 2011. One of the West Memphis Three.[30] Along with Baldwin and Misskelley, he was convicted in 1994 for the 1993 murders of three 8-year-old boys. He was sentenced to death but always maintained his innocence. After entering the plea, he was sentenced to time served: 18 years and 78 days, and was released that same day.

F edit

H edit

  • Pam Hupp - American woman who murdered Louis Gumpenberger.[45]

J edit

  • Adam Jones – professional American cornerback; entered an Alford plea in 2008 to a felony charge of obstruction of a police officer involving an incident from February 2006.[46] After the plea deal involving the incident with the police officer in Georgia, Jones received a felony conviction.[47][48]

L edit

M edit

  • Darren Mack – entered Alford plea in 2008 to the charge of attempted murder related to shooting of Chuck Weller, family court judge in Washoe County, Nevada.[51] Mack stated in court that he shot the judge on the same day he had cut his wife Charla Mack's throat at his residence in Reno, Nevada.[52]
  • Lee Boyd Malvo – entered Alford plea in 2004 related to Beltway sniper attacks, as part of a plea deal to avoid the death penalty.[53] Malvo's Alford plea was treated as a guilty plea at his sentencing hearing, and he received a term of life in prison for charges of murder and attempted murder.[54]
  • Jessie Misskelley, Jr., Arkansas, 2011, One of the West Memphis Three.[30] Along with Echols and Baldwin, he was convicted of the 1993 murders of three 8-year-old boys in 1994. He was sentenced to life in prison. After entering the plea, he was sentenced to time served: 18 years and 78 days, and was released that same day.
  • Jeff Monson – mixed martial arts fighter, entered an Alford plea related to the act of using spray-paint to add graffiti to the armed services recruitment center in Lacey, Washington.[55] In addition to the Alford plea to spray-painting the military recruiting building, Monson also pleaded guilty to first-degree malicious mischief for painting an anarchist symbol at the Washington State Capitol.[56]
  • John Michael Montgomery – country music singer, entered an Alford plea in 2006, on charges related to drunken driving.[57] Montgomery acknowledged that prosecutors in the case had sufficient evidence to convict him of the charges, agreed to pay fines and court costs and was ordered to finish an education session about alcohol usage.[58]
  • Alex Murdaugh - After being convicted of murdering his wife and youngest son, Murdaugh entered into a plea deal to resolve the remaining state-level charges against him that related to his decade of thefts from his clients and law partners. Murdaugh pleaded guilty to 21 of the charges, and entered into an Alford plea for one charge that regarded his alleged theft from his brother. In exchange, the approximately 88 remaining charges against him were dropped. Murdaugh received a 27-year sentence, to run concurrent with the two life sentences he is already serving. [59]

P edit

  • Ruben Patterson – American professional basketball player; entered an Alford plea in 2001 while in Seattle, Washington, on a charge related to an incident with his children's nanny.[60] He had been charged by prosecutors in King County, Washington, with third-degree attempted rape, after the nanny stated to police that Patterson forced her to perform oral sex on him.[61] Patterson received a sentence of 15 days in jail.[61] Patterson was mandated to register as a sex offender in Washington.[60]
  • Michael Peterson - American novelist; On February 24, 2017, Peterson entered an Alford Plea to the voluntary manslaughter of Kathleen Peterson. The judge sentenced him to a maximum of 86 months in prison, with credit for time previously served. Because Peterson had already served more time than the sentence, he did not face additional prison time.

R edit

  • Bhagwan Shree Rajneesh – later called Osho. Founder of Rajneesh movement. – entered an Alford plea and convicted on charges of immigration fraud.[62] Fined $400,000 and deported from the United States in 1985, returned to his native India.[63][64][65][66][67][68]
  • Tina Resch, also known as Christina Boyer – entered an Alford plea to charges of aggravated assault and felony murder of Amber Bennet, Resch's three-year-old daughter.[69] She received a jail sentence of life plus 20 years.[69] Resch had previously been known for being related to possible poltergeist activity, and she was studied by a parapsychologist.[70]
  • Koren Robinson – American football wide receiver, entered an Alford plea in 2007 related to a felony charge of evading police, after an incident involving a high speed car chase.[71] Under a plea deal, Robinson agreed to plead guilty to one felony charge of fleeing police, and prosecutors agreed to dismiss other charges including drunken driving, reckless driving and driving without a licence.[72]
  • Scott Rosenberg – film screenwriter; along with actor Vince Vaughn, entered an Alford plea in relation to a fight that occurred in a bar in Wilmington, North Carolina.[73] The dispute occurred while the two were in the area filming Domestic Disturbance.[74]
  • Kelly Ryan – fitness professional, entered an Alford plea in 2008 in the death of Melissa James.[75] James died in 2005; her body was found in a luxury vehicle in the desert outside Las Vegas, Nevada.[76] As part of the Alford plea, Ryan pleaded guilty to battery with a deadly weapon resulting in significant bodily harm.[76]

V edit

W edit

  • West Memphis Three, Arkansas 2011. See Damien Echols, Jessie Misskelley, Jr. and Jason Baldwin.[30] All three were convicted of the 1993 murders of three 8-year-old boys in 1994. In 2011 they agreed to an Alford plea to get Echols off death row and get out of prison. They maintain that they are innocent and will continue with their investigations on looking for the real killer and clear their names. As part of the deal, they were released that same day, they must serve 10 years probation, cannot seek civil litigations against the state, cannot profit off their story, and will be sent back to prison for another 21 years if they re-offend.

See also edit

References edit

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  3. ^ Huff, C. Ronald; Martin Killias (2008). Wrongful Conviction. Temple University Press. pp. 143, 289. ISBN 978-1-59213-645-2.
  4. ^ a b Daly, Kathleen (1996). Gender, Crime, and Punishment. Yale University Press. p. 20. ISBN 0-300-06866-2.
  5. ^ Thompson, Norma (2006). Unreasonable Doubt. University of Missouri Press. p. 38. ISBN 0-8262-1638-2.
  6. ^ Neighbors, Ira; Anne Chambers; Ellen Levin; Gila Nordman; Cynthia Tutrone (2002). Social Work and the Law. Routledge. p. 18. ISBN 978-0-7890-1548-8.
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  8. ^ Anderson, James F. (2002). Criminal Justice and Criminology: Concepts and Terms. University Press of America. p. 7. ISBN 0-7618-2224-0.
  9. ^ Wild, Susan Ellis (2006). Webster's New World Law Dictionary. Webster's New World. p. 21. ISBN 0-7645-4210-9.
  10. ^ Bibas, Stephanos (2003). "Harmonizing Substantive Criminal Law Values and Criminal Procedure: The Case of Alford and Nolo Contendere Pleas". Cornell Law Review. 88 (6). doi:10.2139/ssrn.348681.
  11. ^ Champion, Dean J. (1998). Dictionary of American Criminal Justice: Key Terms and Major Supreme Court Cases. Routledge. p. 7. ISBN 1-57958-073-4.
  12. ^ Gardner, Thomas J.; Terry M. Anderson (2009). Criminal Evidence: Principles and Cases. Wadsworth Publishing. p. 50. ISBN 978-0-495-59924-1.
  13. ^ Fisher, George (2003). Plea Bargaining's Triumph: A History of Plea Bargaining in America. Stanford University Press. p. 319. ISBN 0-8047-5135-8.
  14. ^ Davidson, Michael J. (1999). A Guide to Military Criminal Law. US Naval Institute Press. p. 56. ISBN 1-55750-155-6.
  15. ^ Raymond, Walter John (1992). Dictionary of Politics: Selected American and Foreign Political and Legal Terms. Brunswick Publishing Corporation. p. 9. ISBN 978-1-55618-008-8.
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  17. ^ a b c d e f g Potts, Monica (October 18, 2009). "Alford plea a common method of resolving cases". The Connecticut Post. Bridgeport, Connecticut.
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  19. ^ a b c d e f g Weigl, Andrea (February 21, 2007). "What is an alford plea ?". The News & Observer. Raleigh, North Carolina: The News & Observer Pub. Co. p. A12.
  20. ^ a b c Susnjara, Bob (August 15, 1997). "Alford plea often benefits both sides". The News-Sun. Waukegan, Illinois. p. A2.
  21. ^ a b Hogan, Dick (November 8, 1992). "Supreme Court case set plea". The Gazette. Cedar Rapids-Iowa City: Cedar Rapids Gazette. p. A19.
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  23. ^ a b c Ford, Steve (February 25, 2007). "Follow the bouncing plea bargain". The News & Observer. Raleigh, North Carolina: The News & Observer Pub. Co. p. A26.
  24. ^ a b c d e f Ovaska, Sarah (February 23, 2007). "Alford pleas fuse dignity, denial". The News & Observer. Raleigh, North Carolina: The News & Observer Pub. Co. p. B1.
  25. ^ "Abaroa pleads guilty but maintains innocence in wife's 2005 death". 12 March 2014.
  26. ^ Effron, Lauren. "How contact lenses blew a 2005 murder case wide open and led to a husband serving prison time". ABC News. Retrieved 2021-11-24.
  27. ^ a b c Richter, Shawna; John Mangalonzo (June 9, 2008). "History behind the Alford plea". The Hawk Eye. Burlington, Iowa. p. 4A.
  28. ^ Seattle Post-Intelligencer staff (December 6, 2003). "Actor pleads to lesser charge in child-rape case". Seattle Post-Intelligencer. www.seattlepi.com. Retrieved 2009-11-30.
  29. ^ Whitely, Peyton (January 17, 2004). "Actor gets 4 months for assault in sex case". The Seattle Times. seattletimes.nwsource.com. Retrieved 2009-11-30.
  30. ^ a b c d New York Times Deal Frees ‘West Memphis Three’ in Arkansas (2011-08-19)
  31. ^ Robertson, Gary D. (July 16, 2009). "NC judge sentences Black to more prison time". AP Alert – Political. Associated Press.
  32. ^ "Former N.C. speaker begins prison term". AFX UK ProFeed. AFX News Limited. July 30, 2007.
  33. ^ Risen, James; Judy Thomas (1999). Wrath Of Angels: The American Abortion War. Basic Books. pp. 96, 99. ISBN 978-0-465-09273-4.
  34. ^ a b Blanchard, Dallas A.; Terry James Prewitt (1993). Religious Violence and Abortion. University Press of Florida. p. 298. ISBN 0-8130-1193-0.
  35. ^ a b Levy, Paul (September 3, 2005). "Former Viking's charges reduced; In plea, Brown won't face trial on Arctic Blast sexual-assault charge". Star Tribune. Minneapolis, Minnesota.
  36. ^ Levy, Paul (September 10, 2005). "County challenges plea by ex-Viking Brown". Star Tribune. Minneapolis, Minnesota. p. 9B.
  37. ^ Meryhew, Richard (February 15, 2006). "Appeals Court says no deal to Arctic Blast plea bargain – Former Vikings star may have to face charges of criminal sexual assault after all". Star Tribune. Minneapolis, Minnesota. p. 4B.
  38. ^ "Offset of Migos Has Been Released From Jail (UPDATED)". Complex. Retrieved 2022-08-12.
  39. ^ a b Cooper, Bob (November 3, 2003). . Office of Attorney General Lawrence Wasden. State of Idaho. Archived from the original on October 1, 2009. Retrieved 2009-11-30.
  40. ^ The Spokesman-Review staff (February 15, 2003). "Boise Mayor, already under fire, quits amid Olympic charges". The Spokesman-Review. p. B1.
  41. ^ a b Stockwell, Jamie (August 10, 2006). "30-Year Sentence In Slaying Of Student". The Washington Post. Retrieved 2009-11-30.
  42. ^ "Judge refuses to throw out sentence in Taylor Behl murder". Richmond Times-Dispatch. WTOP. Associated Press. November 18, 2008. Retrieved 2009-11-30.
  43. ^ a b "Rep. Bob Filner Enters 'Alford' Plea to Trespassing Charge Stemming From Airport Altercation". Fox News Channel. www.foxnews.com. Associated Press. November 26, 2007. Retrieved 2009-12-01.
  44. ^ Bresnahan, John (November 26, 2007). "Filner Cops To Trespassing, Will Pay Fine". Politico. CBS News. Retrieved 2009-12-01.
  45. ^ Singer, Cathy (June 19, 2019). "Pam Hupp avoids death penalty with plea, faces life in prison for 2016 murder of Louis Gumpenberger". NBC. Retrieved June 30, 2019.
  46. ^ ESPN.com news services (March 21, 2008). "Cowboys, Titans reportedly engaged in Pacman talks". ESPN. sports.espn.go.com. Retrieved 2009-12-01.
  47. ^ "Jones delays filing for NFL reinstatement until possible trade". The Hamilton Spectator. Ontario, Canada. Associated Press. April 16, 2008. p. SP13.
  48. ^ The Toronto Star staff (February 15, 2008). "Prosecutor: Pacman a convicted felon – Suspended Titan settles last of six charges; former QB subdued". The Toronto Star. Ontario, Canada: Toronto Star Newspapers Limited. p. S06.
  49. ^ a b Reinitz, Jeff (December 17, 2005). "Man pleads to slaying". The Courier. www.wcfcourier.com. Retrieved 2009-11-30.
  50. ^ KWWL staff (March 15, 2005). "Murder investigation in Waterloo". KWWL. Quincy Newspapers.
  51. ^ "$590 million for daughter, slain mom's estate". NBC News. NBC News. Associated Press. March 19, 2008. Retrieved 2009-11-30.
  52. ^ "Reno jury returns with $590 million judgement against Mack". San Francisco Chronicle. www.sfgate.com. Associated Press. March 18, 2008.
  53. ^ "Malvo pleads to 2002 sniper killing". NBC News. NBC News. Associated Press. October 26, 2004. Retrieved 2009-11-30.
  54. ^ CNN staff (October 27, 2004). "Malvo gets life sentence in sniper killing". CNN. www.cnn.com. Retrieved 2009-11-30. {{cite news}}: |last= has generic name (help)
  55. ^ "Ex-UFC fighter Monson pleads guilty to mischief, could face jail". USA Today. www.usatoday.com. Associated Press. July 29, 2009. Retrieved 2009-11-30.
  56. ^ UPI staff (July 29, 2009). "Fighting champ admits anarchist graffiti". United Press International. www.upi.com. Retrieved 2009-11-30.
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  58. ^ Seattle Post-Intelligencer staff (August 24, 2006). "This may be the start of a hit song. Title: "You Say I'm Guilty, I Say I'm Not."". Seattle Post-Intelligencer. p. E2.
  59. ^ Monk, John. "Murdaugh admits committing state financial crimes. Here are details of his plea deal". The State. Retrieved 2023-12-31.
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  69. ^ a b Horn, Sue (January 20, 2008). "The real story of Christina Resch Boyer: Did a "perfect storm" of events lead to life imprisonment?". Carroll Star News. Carrollton, Georgia: The Georgia Rail and Press Company. p. 1.
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  72. ^ Canadian Press staff (January 23, 2007). "Former Vikings receiver Robinson enters plea in police chase". The Canadian Press.
  73. ^ a b The Providence Journal staff (June 5, 2001). "People". The Providence Journal. p. F2.
  74. ^ a b Dayton Daily News staff (June 2, 2001). "Vince Vaughn, writer enter pleas in brawl". Dayton Daily News. Dayton, Ohio. p. 2A.
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Further reading edit

  • McConville, Mike (1998). "Plea Bargainings: Ethics and Politics". Journal of Law and Society. 25 (4): 562–587. doi:10.1111/1467-6478.00103. S2CID 146427753.
  • Shipley, Curtis J. (1987). "The Alford Plea: A Necessary But Unpredictable Tool for the Criminal Defendant". Iowa Law Review. 72: 1063. ISSN 0021-0552.
  • Ward, Bryan H. (2003). "A Plea Best Not Taken: Why Criminal Defendants Should Avoid the Alford Plea". Missouri Law Review. 68: 913. ISSN 0026-6604.

External links edit

 
Wikisource has original text related to this article:
North Carolina v. Alford
Court cases

January 01, 1970
list, people, entered, alford, plea, following, incomplete, list, notable, individuals, that, have, entered, alford, plea, alford, plea, also, referred, alford, guilty, plea, alford, doctrine, united, states, guilty, plea, criminal, court, where, defendant, do. The following is an incomplete list of notable individuals that have entered an Alford plea An Alford plea also referred to as Alford guilty plea 1 2 3 and Alford doctrine 4 5 6 in the law of the United States is a guilty plea in criminal court 7 8 9 where the defendant does not admit the act and asserts innocence 10 11 12 Under the Alford plea the defendant admits that sufficient evidence exists with which the prosecution could likely convince a judge or jury to find the defendant guilty beyond a reasonable doubt 4 13 14 15 16 Contents Background Supreme Court case Usage of plea A B C D E F G H I J K L M N O P Q R S T U V W X Y Z Further reading See also Notes References External linksBackground editSupreme Court case edit nbsp Supreme Court Justice Byron White wrote the majority opinion This form of plea is derived from the 1970 ruling by the Supreme Court of the United States in the case North Carolina v Alford 17 Henry Alford of Forsyth County North Carolina was indicted for first degree murder in 1963 18 19 At the time under North Carolina law a conviction of first degree murder automatically brought with it the death penalty unless the jury recommended otherwise in which case the defendant would receive a mandatory life sentence 20 21 Alford said he was innocent but the prosecution had significant evidence to the contrary 19 Witnesses stated Alford had said he wanted to kill the victim then grabbed his gun and left his residence 19 Witnesses said that Alford subsequently declared he had killed the victim 19 His defense advised Alford to plead to the crime of second degree murder because of the belief that the strong evidence would lead to a conviction 19 He pleaded guilty to second degree murder in 1963 18 He did so in order to avoid a possible death sentence 18 Alford maintained he was innocent of the crime itself but feared going to trial because of the capital punishment associated with the charge of first degree murder 22 He was given a sentence of thirty years in jail 18 Alford appealed and argued that his conviction for second degree murder should be overturned because he said the plea was coercive in nature 23 The matter came before the Supreme Court and in its ruling the court said that the trial judge in Alford s criminal case was appropriate in having accepted the defendant s plea of guilty 18 The Court said that the decision to plead guilty while maintaining his innocence was a reasonable choice for Alford to have made at the time 23 Supreme Court Justice Byron White wrote the majority opinion 18 The Supreme Court case was decided 5 3 18 T hat he would not have pleaded except for the opportunity to limit the possible penalty does not necessarily demonstrate that the plea of guilty was not the product of a free and rational choice said the Supreme Court decision 22 The Court ruled that a plea of guilty that was a voluntary and intelligent choice among the alternative courses of action was not a coercive decision 21 Justice White wrote that Express admission of guilt is not constitutional requisite to imposition of criminal penalty 20 In 1975 Alford died while in jail at the age of 57 19 Usage of plea edit When a defendant indicates an intention to plead guilty by Alford plea the judge asks two questions Do you now consider it to be in your best interest to plead guilty and Do you understand that upon your Alford plea you will be treated as being guilty whether or not you admit that you are in fact guilty 19 Prosecutors and defense lawyers characterize Alford pleas as a required method of lessening pressure of the nature of the justice process 17 Both parties get to maneuver around not knowing what the outcome could be at trial and are able to come to a resolution 17 The Alford plea does not itself affect the sentencing process and the convicted individual is sentenced just as if he had entered a normal guilty plea 18 20 The defendant may be hurt at the sentencing process by having used an Alford plea as the judge may see this as a sign that the defendant has not accepted responsibility for his actions 24 Duke University law professor Robert P Mosteller commented on this possible effect at sentencing They get you more harm than good 24 Orange County North Carolina District Attorney Jim Woodall said that the frequency of Alford pleas is higher with criminal cases involving a charge of a sexual offense as the defendant does not wish to admit to their family and the public that they were responsible for the crime 24 Psychologist Bob Carbo noted that sexual offenders undergoing treatment for their actions after being ordered to so under terms of their Alford plea cause problems because the first step in therapy is to take responsibility for committing the crime 24 We can t help this person if they re not willing to admit they did something said Carbo 24 John Gulash a lawyer on the Connecticut State Bar Association s criminal justice executive committee acknowledged It s unfortunate but it s a reality that you will receive in most instances a much more severe penalty if you lost after trial than if you pled before the trial 17 Defendants gain the potential benefit of being able to tell possible employers after their conviction in a crime that they maintained their innocence and only pleaded guilty under the Alford doctrine because of the nature of the situation and the evidence presented 17 Professor of law at Quinnipiac University and former federal prosecutor Jeffrey Meyer said of the Alford doctrine It s part of an idealist vision of a judicial system that it is for the adjudication of truth 17 Meyer commented on what would happen were the Alford doctrine to become no longer applicable My suspicion is if the state could dispense with the Alford doctrine over time it probably wouldn t change very much the rate at which cases plead out More than 95 percent of cases in federal court go by guilty plea It s difficult to make the case that without the Alford doctrine there would be an immense number of defendants who would end up going to trial 17 Raleigh North Carolina lawyer Wade Smith said that the frequency of application of the Alford plea is Fairly often There are many times when people don t want to plead guilty but then do in fact plead guilty 18 List editThis is a dynamic list and may never be able to satisfy particular standards for completeness You can help by adding missing items with reliable sources A edit Raven Abaroa The jury was deadlocked in Raven Abaroa s 2013 trial for the murder of his wife Janet When the state of North Carolina offered him a deal shortly before his second trial was to begin he took it saying I didn t receive a fair trial the first time and I don t think I ll receive a fair trial the second time Abaroa was sentenced to 95 to 123 months in prison for the crime of voluntary manslaughter and ended up serving approximately 7 years 25 26 Henry Alford indicted for first degree murder in 1963 maintained his innocence but pleaded guilty to second degree murder due to the significance of the evidence 27 He pleaded guilty to second degree murder so as to avoid the death penalty 23 Alford appealed and the Supreme Court of the United States issued a ruling that trial courts are allowed to accept pleas of guilty from criminal defendants even if the defendants do not wish to admit to guilty and wish to plead guilty in order to take advantage of a plea deal 27 This type of plea described by the 1970 ruling of the Supreme Court became known as the Alford plea 27 John Dylan Adams entered an Alford plea in the kidnapping rape and killing of 20 year old nursing student Holly Lynn Bobo Adams is currently April 2018 serving a 35 year sentence without parole in the Tennessee Department of Correction 1 B edit Scott Bairstow actor of Party of Five fame entered Alford plea in 2003 to second degree assault was initially charged with second degree child rape of 12 year old girl 28 He received a sentence of four months in jail for the assault 29 Jason Baldwin Arkansas 2011 One of the West Memphis Three 30 Along with Echols and Misskelley he was convicted of the 1993 murders of three 8 year old boys in 1994 He was sentenced to life without parole He entered the plea to get Echols off death row He was sentenced to time served 18 years and 78 days and released that same day James B Black former Speaker of the North Carolina House of Representatives gave an Alford plea in 2007 on charges brought by the state of North Carolina of obstruction of justice and bribery 24 31 Black was accused of bribing former state Representative Michael Decker 50 000 to switch his political allegiance thereby keeping Black in power as co Speaker of the House 32 Michael Bray American anti abortion activist he was arrested by U S federal law enforcement from the ATF in connection with an anti abortion bombing 33 He entered an Alford plea in 1987 and received a prison sentence of six years 34 He served just over forty six months in a federal jail 34 Ted Brown American and former collegiate and professional football player played for the Minnesota Vikings 35 After being charged with criminal sexual assault in an incident in Mille Lacs County Minnesota Brown entered an Alford plea on a lesser charge and agreed to perform 100 hours of community service 35 Mille Lacs County challenged the plea deal 36 and in 2006 a ruling from the Minnesota Court of Appeals overturned it after the woman involved in the incident told prosecutors she did not approve of the deal 37 C edit Kiari Cephus rapper known as Offset entered an Alford plea in December 2015 to felony battery and inciting a riot within a penal facility in exchange for dismissing criminal charges in relation to an April 2015 arrest at the Georgia Southern University for drug and firearm possession 38 Raymond Clark III the perpetrator in the murder of Annie Le H Brent Coles former Mayor of Boise Idaho entered an Alford plea to two felony charges of presenting a fraudulent account or voucher and misuse of public money by officers 39 The plea was made in accordance with a deal by the State Attorney General of Idaho 39 Coles had resigned from his position as mayor amidst complaints filed against him by the State Attorney General s office 40 E edit Damien Echols Arkansas 2011 One of the West Memphis Three 30 Along with Baldwin and Misskelley he was convicted in 1994 for the 1993 murders of three 8 year old boys He was sentenced to death but always maintained his innocence After entering the plea he was sentenced to time served 18 years and 78 days and was released that same day F edit Benjamin Fawley entered an Alford plea in 2006 to second degree murder in the Murder of Taylor Behl 41 He received a sentence of 30 years in jail 41 In November 2008 a judge rejected a petition by Fawley to have his sentence thrown out 42 Bob Filner Democratic politician who represents California s 51st Congressional District in the U S House of Representatives entered an Alford plea in 2007 to charges of trespassing 43 He had faced charges of assault and battery crime in an incident where a baggage handler for United Airlines at Dulles International Airport said he had pushed her 43 Filner was investigated in the matter by an ethics committee for the U S House of Representatives 44 H edit Pam Hupp American woman who murdered Louis Gumpenberger 45 J edit Adam Jones professional American cornerback entered an Alford plea in 2008 to a felony charge of obstruction of a police officer involving an incident from February 2006 46 After the plea deal involving the incident with the police officer in Georgia Jones received a felony conviction 47 48 L edit Joseph Lawrence entered Alford plea to second degree murder in 2005 the Murder of Jason Gage 49 He had been arrested hours after Gage s dead body was discovered 50 Lawrence was sentenced to a term of 50 years in prison 49 M edit Darren Mack entered Alford plea in 2008 to the charge of attempted murder related to shooting of Chuck Weller family court judge in Washoe County Nevada 51 Mack stated in court that he shot the judge on the same day he had cut his wife Charla Mack s throat at his residence in Reno Nevada 52 Lee Boyd Malvo entered Alford plea in 2004 related to Beltway sniper attacks as part of a plea deal to avoid the death penalty 53 Malvo s Alford plea was treated as a guilty plea at his sentencing hearing and he received a term of life in prison for charges of murder and attempted murder 54 Jessie Misskelley Jr Arkansas 2011 One of the West Memphis Three 30 Along with Echols and Baldwin he was convicted of the 1993 murders of three 8 year old boys in 1994 He was sentenced to life in prison After entering the plea he was sentenced to time served 18 years and 78 days and was released that same day Jeff Monson mixed martial arts fighter entered an Alford plea related to the act of using spray paint to add graffiti to the armed services recruitment center in Lacey Washington 55 In addition to the Alford plea to spray painting the military recruiting building Monson also pleaded guilty to first degree malicious mischief for painting an anarchist symbol at the Washington State Capitol 56 John Michael Montgomery country music singer entered an Alford plea in 2006 on charges related to drunken driving 57 Montgomery acknowledged that prosecutors in the case had sufficient evidence to convict him of the charges agreed to pay fines and court costs and was ordered to finish an education session about alcohol usage 58 Alex Murdaugh After being convicted of murdering his wife and youngest son Murdaugh entered into a plea deal to resolve the remaining state level charges against him that related to his decade of thefts from his clients and law partners Murdaugh pleaded guilty to 21 of the charges and entered into an Alford plea for one charge that regarded his alleged theft from his brother In exchange the approximately 88 remaining charges against him were dropped Murdaugh received a 27 year sentence to run concurrent with the two life sentences he is already serving 59 P edit Ruben Patterson American professional basketball player entered an Alford plea in 2001 while in Seattle Washington on a charge related to an incident with his children s nanny 60 He had been charged by prosecutors in King County Washington with third degree attempted rape after the nanny stated to police that Patterson forced her to perform oral sex on him 61 Patterson received a sentence of 15 days in jail 61 Patterson was mandated to register as a sex offender in Washington 60 Michael Peterson American novelist On February 24 2017 Peterson entered an Alford Plea to the voluntary manslaughter of Kathleen Peterson The judge sentenced him to a maximum of 86 months in prison with credit for time previously served Because Peterson had already served more time than the sentence he did not face additional prison time R edit Bhagwan Shree Rajneesh later called Osho Founder of Rajneesh movement entered an Alford plea and convicted on charges of immigration fraud 62 Fined 400 000 and deported from the United States in 1985 returned to his native India 63 64 65 66 67 68 Tina Resch also known as Christina Boyer entered an Alford plea to charges of aggravated assault and felony murder of Amber Bennet Resch s three year old daughter 69 She received a jail sentence of life plus 20 years 69 Resch had previously been known for being related to possible poltergeist activity and she was studied by a parapsychologist 70 Koren Robinson American football wide receiver entered an Alford plea in 2007 related to a felony charge of evading police after an incident involving a high speed car chase 71 Under a plea deal Robinson agreed to plead guilty to one felony charge of fleeing police and prosecutors agreed to dismiss other charges including drunken driving reckless driving and driving without a licence 72 Scott Rosenberg film screenwriter along with actor Vince Vaughn entered an Alford plea in relation to a fight that occurred in a bar in Wilmington North Carolina 73 The dispute occurred while the two were in the area filming Domestic Disturbance 74 Kelly Ryan fitness professional entered an Alford plea in 2008 in the death of Melissa James 75 James died in 2005 her body was found in a luxury vehicle in the desert outside Las Vegas Nevada 76 As part of the Alford plea Ryan pleaded guilty to battery with a deadly weapon resulting in significant bodily harm 76 V edit Vince Vaughn actor with Scott Rosenberg entered an Alford plea after altercation at a bar in North Carolina while filming Domestic Disturbance 73 74 W edit West Memphis Three Arkansas 2011 See Damien Echols Jessie Misskelley Jr and Jason Baldwin 30 All three were convicted of the 1993 murders of three 8 year old boys in 1994 In 2011 they agreed to an Alford plea to get Echols off death row and get out of prison They maintain that they are innocent and will continue with their investigations on looking for the real killer and clear their names As part of the deal they were released that same day they must serve 10 years probation cannot seek civil litigations against the state cannot profit off their story and will be sent back to prison for another 21 years if they re offend See also edit nbsp Law portal Alternative pleading Deferred Adjudication Insanity defense Malum in se Malum prohibitum Peremptory pleaReferences edit Shepherd Robert E Jr November 2000 Annual Survey of Virginia Law Article Legal issues involving children University of Richmond Law Review 34 University of Richmond Law Review Association 939 Editor The Montana Lawyer February 1998 Regular Features Discipline Corner Disbarment follows four years of disciplinary action against Kalispell lawyer The Montana Lawyer 23 State Bar of Montana 23 a href Template Cite journal html title Template Cite journal cite journal a last has generic name help Huff C Ronald Martin Killias 2008 Wrongful Conviction Temple University Press pp 143 289 ISBN 978 1 59213 645 2 a b Daly Kathleen 1996 Gender Crime and Punishment Yale University Press p 20 ISBN 0 300 06866 2 Thompson Norma 2006 Unreasonable Doubt University of Missouri Press p 38 ISBN 0 8262 1638 2 Neighbors Ira Anne Chambers Ellen Levin Gila Nordman Cynthia Tutrone 2002 Social Work and the Law Routledge p 18 ISBN 978 0 7890 1548 8 Scheb John 2008 Criminal Procedure Wadsworth Publishing p 148 ISBN 978 0 495 50386 6 Anderson James F 2002 Criminal Justice and Criminology Concepts and Terms University Press of America p 7 ISBN 0 7618 2224 0 Wild Susan Ellis 2006 Webster s New World Law Dictionary Webster s New World p 21 ISBN 0 7645 4210 9 Bibas Stephanos 2003 Harmonizing Substantive Criminal Law Values and Criminal Procedure The Case of Alford and Nolo Contendere Pleas Cornell Law Review 88 6 doi 10 2139 ssrn 348681 Champion Dean J 1998 Dictionary of American Criminal Justice Key Terms and Major Supreme Court Cases Routledge p 7 ISBN 1 57958 073 4 Gardner Thomas J Terry M Anderson 2009 Criminal Evidence Principles and Cases Wadsworth Publishing p 50 ISBN 978 0 495 59924 1 Fisher George 2003 Plea Bargaining s Triumph A History of Plea Bargaining in America Stanford University Press p 319 ISBN 0 8047 5135 8 Davidson Michael J 1999 A Guide to Military Criminal Law US Naval Institute Press p 56 ISBN 1 55750 155 6 Raymond Walter John 1992 Dictionary of Politics Selected American and Foreign Political and Legal Terms Brunswick Publishing Corporation p 9 ISBN 978 1 55618 008 8 Judge Michael T Stephen R McCullough November 2009 Criminal law and procedure University of Richmond Law Review 44 University of Richmond Law Review Association 339 a b c d e f g Potts Monica October 18 2009 Alford plea a common method of resolving cases The Connecticut Post Bridgeport Connecticut a b c d e f g h i Ingram David February 20 2007 The Alford Plea The Charlotte Observer Charlotte North Carolina p 9A a b c d e f g Weigl Andrea February 21 2007 What is an alford plea The News amp Observer Raleigh North Carolina The News amp Observer Pub Co p A12 a b c Susnjara Bob August 15 1997 Alford plea often benefits both sides The News Sun Waukegan Illinois p A2 a b Hogan Dick November 8 1992 Supreme Court case set plea The Gazette Cedar Rapids Iowa City Cedar Rapids Gazette p A19 a b Lithwick Dahlia November 5 2001 Can You Plead Guilty and Maintain Your Innocence Slate Washingtonpost Newsweek Interactive Co LLC p Section Explainer a b c Ford Steve February 25 2007 Follow the bouncing plea bargain The News amp Observer Raleigh North Carolina The News amp Observer Pub Co p A26 a b c d e f Ovaska Sarah February 23 2007 Alford pleas fuse dignity denial The News amp Observer Raleigh North Carolina The News amp Observer Pub Co p B1 Abaroa pleads guilty but maintains innocence in wife s 2005 death 12 March 2014 Effron Lauren How contact lenses blew a 2005 murder case wide open and led to a husband serving prison time ABC News Retrieved 2021 11 24 a b c Richter Shawna John Mangalonzo June 9 2008 History behind the Alford plea The Hawk Eye Burlington Iowa p 4A Seattle Post Intelligencer staff December 6 2003 Actor pleads to lesser charge in child rape case Seattle Post Intelligencer www seattlepi com Retrieved 2009 11 30 Whitely Peyton January 17 2004 Actor gets 4 months for assault in sex case The Seattle Times seattletimes nwsource com Retrieved 2009 11 30 a b c d New York Times Deal Frees West Memphis Three in Arkansas 2011 08 19 Robertson Gary D July 16 2009 NC judge sentences Black to more prison time AP Alert Political Associated Press Former N C speaker begins prison term AFX UK ProFeed AFX News Limited July 30 2007 Risen James Judy Thomas 1999 Wrath Of Angels The American Abortion War Basic Books pp 96 99 ISBN 978 0 465 09273 4 a b Blanchard Dallas A Terry James Prewitt 1993 Religious Violence and Abortion University Press of Florida p 298 ISBN 0 8130 1193 0 a b Levy Paul September 3 2005 Former Viking s charges reduced In plea Brown won t face trial on Arctic Blast sexual assault charge Star Tribune Minneapolis Minnesota Levy Paul September 10 2005 County challenges plea by ex Viking Brown Star Tribune Minneapolis Minnesota p 9B Meryhew Richard February 15 2006 Appeals Court says no deal to Arctic Blast plea bargain Former Vikings star may have to face charges of criminal sexual assault after all Star Tribune Minneapolis Minnesota p 4B Offset of Migos Has Been Released From Jail UPDATED Complex Retrieved 2022 08 12 a b Cooper Bob November 3 2003 Coles Enters Guilty Pleas on Two Felony Charges Office of Attorney General Lawrence Wasden State of Idaho Archived from the original on October 1 2009 Retrieved 2009 11 30 The Spokesman Review staff February 15 2003 Boise Mayor already under fire quits amid Olympic charges The Spokesman Review p B1 a b Stockwell Jamie August 10 2006 30 Year Sentence In Slaying Of Student The Washington Post Retrieved 2009 11 30 Judge refuses to throw out sentence in Taylor Behl murder Richmond Times Dispatch WTOP Associated Press November 18 2008 Retrieved 2009 11 30 a b Rep Bob Filner Enters Alford Plea to Trespassing Charge Stemming From Airport Altercation Fox News Channel www foxnews com Associated Press November 26 2007 Retrieved 2009 12 01 Bresnahan John November 26 2007 Filner Cops To Trespassing Will Pay Fine Politico CBS News Retrieved 2009 12 01 Singer Cathy June 19 2019 Pam Hupp avoids death penalty with plea faces life in prison for 2016 murder of Louis Gumpenberger NBC Retrieved June 30 2019 ESPN com news services March 21 2008 Cowboys Titans reportedly engaged in Pacman talks ESPN sports espn go com Retrieved 2009 12 01 Jones delays filing for NFL reinstatement until possible trade The Hamilton Spectator Ontario Canada Associated Press April 16 2008 p SP13 The Toronto Star staff February 15 2008 Prosecutor Pacman a convicted felon Suspended Titan settles last of six charges former QB subdued The Toronto Star Ontario Canada Toronto Star Newspapers Limited p S06 a b Reinitz Jeff December 17 2005 Man pleads to slaying The Courier www wcfcourier com Retrieved 2009 11 30 KWWL staff March 15 2005 Murder investigation in Waterloo KWWL Quincy Newspapers 590 million for daughter slain mom s estate NBC News NBC News Associated Press March 19 2008 Retrieved 2009 11 30 Reno jury returns with 590 million judgement against Mack San Francisco Chronicle www sfgate com Associated Press March 18 2008 Malvo pleads to 2002 sniper killing NBC News NBC News Associated Press October 26 2004 Retrieved 2009 11 30 CNN staff October 27 2004 Malvo gets life sentence in sniper killing CNN www cnn com Retrieved 2009 11 30 a href Template Cite news html title Template Cite news cite news a last has generic name help Ex UFC fighter Monson pleads guilty to mischief could face jail USA Today www usatoday com Associated Press July 29 2009 Retrieved 2009 11 30 UPI staff July 29 2009 Fighting champ admits anarchist graffiti United Press International www upi com Retrieved 2009 11 30 Singer makes plea deal The Journal Gazette Fort Wayne Indiana Associated Press August 24 2006 Seattle Post Intelligencer staff August 24 2006 This may be the start of a hit song Title You Say I m Guilty I Say I m Not Seattle Post Intelligencer p E2 Monk John Murdaugh admits committing state financial crimes Here are details of his plea deal The State Retrieved 2023 12 31 a b Tomasson Chris March 8 2006 Patterson registers as a sex offender in Colorado Rocky Mountain News p 8C a b Duran Sarah Frank Hughes May 16 2001 Patterson to serve jail time 1 year sentence Sonic to serve 15 days plus register as sex offender The News Tribune Tacoma Washington p C1 Spokane Chronicle staff May 11 1988 Bhagwan Spokane Chronicle p A1 Staff 2007 Oregon History Chronology 1952 to 2002 Oregon Blue Book Directory and Fact Book compiled by the Oregon State Archives Retrieved 2007 11 22 Staff Wasco County History Oregon Historical County Records Guide Oregon State Archives Retrieved 2007 11 22 Gross Jane January 25 1989 Seattle Journal With Guru Deported Disciples Struggle On The New York Times Retrieved December 1 2009 Last fugitive in case against Oregon cult members appears in court CNN Associated Press December 21 2002 Ostrom Carol M December 11 1995 Years Later Bitterness Endures At Rancho Rajneesh The Seattle Times Retrieved 2008 11 09 Lattin Don June 15 2005 10 hour wait 3 second hug Motherly guru draws throngs of seekers to East Bay temple San Francisco Chronicle Retrieved 2008 11 09 a b Horn Sue January 20 2008 The real story of Christina Resch Boyer Did a perfect storm of events lead to life imprisonment Carroll Star News Carrollton Georgia The Georgia Rail and Press Company p 1 Roll William December 2004 Tina Resch Unleashed Fortean Times www forteantimes com Archived from the original on 2009 06 05 Retrieved 2009 11 30 AP staff January 24 2007 Former Seahawks wide receiver enters plea in police chase AP Alert Washington Associated Press Canadian Press staff January 23 2007 Former Vikings receiver Robinson enters plea in police chase The Canadian Press a b The Providence Journal staff June 5 2001 People The Providence Journal p F2 a b Dayton Daily News staff June 2 2001 Vince Vaughn writer enter pleas in brawl Dayton Daily News Dayton Ohio p 2A Ritter Ken August 22 2008 Pro bodybuilders sentenced in aide s 2005 death in Vegas AP Alert Associated Press a b Hennessey Kathleen June 1 2008 Bodybuilding couple pleads in assistants death Houston Chronicle p A28 Further reading editMcConville Mike 1998 Plea Bargainings Ethics and Politics Journal of Law and Society 25 4 562 587 doi 10 1111 1467 6478 00103 S2CID 146427753 Shipley Curtis J 1987 The Alford Plea A Necessary But Unpredictable Tool for the Criminal Defendant Iowa Law Review 72 1063 ISSN 0021 0552 Ward Bryan H 2003 A Plea Best Not Taken Why Criminal Defendants Should Avoid the Alford Plea Missouri Law Review 68 913 ISSN 0026 6604 External links edit nbsp Wikisource has original text related to this article North Carolina v Alford Alford Doctrine State of Connecticut Judicial Branch USAM 9 16 000 Pleas Federal Rule of Criminal Procedure 11 United States Department of Justice Issue Effect of Alford Plea of Guilty Issues In NY Criminal Law Volume 4 Issue 11 Transcript Of Plea Form North Carolina with question about term Court cases North Carolina v Alford Supreme Court of the United States US v Szucko Definition of term by United States Court of Appeals for the Fifth Circuit US v Bierd Definition of term by United States Court of Appeals for the First Circuit Retrieved from https en wikipedia org w index php title List of people who entered an Alford plea amp oldid 1192890150, wikipedia, wiki, book, books, library,

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