In 1970, the United States Supreme Court decided in North Carolina v. Alford that an express admission of guilt is not a constitutional requisite to the imposition of a criminal penalty. An individual accused of a 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.
The court held that the constitution allowed trial courts to accept such a plea, even where procedural rules require “a sufficient factual basis” to justify the court’s acceptance of a plea when a defendant still claims innocence, but left room for the trial court’s discretion in accepting such a plea by stating, “A criminal defendant does not have an absolute right under the [c]onstitution to have his guilty plea accepted by the court [but] … a trial judge [has] discretion to ‘refuse to accept a plea of guilty.’” The Court did not find it necessary to delineate the scope of that discretion and left it to developing case law.
