Alford plea (Utah) · Go Syfert
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Alford plea in Utah

13 Utah opinions name it 2 courts 1993–2023 2 in the last five years

The cases below were cited by Utah courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
North Carolina v. Alfordgreen
scotus · 1970 · cited in 8 Utah opinions naming this issue, 1993–2019
2 sentences

2019An Alford plea is a type of guilty plea in which “a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” These pleas allow courts to impose “a prison sentence upon an accused who is unwilling expressly to admit his guilt but who, faced with grim alternatives, is willing to waive his trial and accept the sentence.” State v. Gardner, 2018 UT App 126 , ¶ 9 n.5, 428 P.3d 58 (quoting North Carolina v. Alford, 400 U.S. 25 , 35–36 (1970)); see also State v. Ott, 2010 UT 1 , ¶ 9 n

2018From all that appears in the record, the officers in fact did have probable cause to arrest him, given the report from Victim that was corroborated by Gardner's son. 5 An Alford plea, or a plea of no contest or nolo contendere, is "a plea by which a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty." North Carolina v. Alford , 400 U.S. 25 , 35, 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970).

48
State v. Stillinggreen
utahctapp · 1993 · cited in 3 Utah opinions naming this issue, 2003–2014
2 sentences

2014Because a defendant “necessarily does not admit to all elements of the charged crimes” when entering an Alford plea, “the record must be sufficient to satisfy the trial court and/or a reviewing court that the State’s case is strong enough to warrant acceptance of the plea when guilt is not admitted by the defendant.” State v. Stilling, 856 P.2d 666, 674 (Utah Ct.App.1993).

2011P. 11(b) ("A defendant may plead ... guilty [or] no contest."); State v. Stilling, 856 P.2d 666, 671-72 (Utah Ct.App.1993) (explaining that an Alford plea is where a defendant enters a plea without admitting guilt to the offense charged (citing North Carolina v. Alford, 400 U.S. 25, 38 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970))).

33
State v. Ottgreen
utah · 2010 · cited in 4 Utah opinions naming this issue, 2013–2019
2 sentences

2019An Alford plea is a type of guilty plea in which “a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” These pleas allow courts to impose “a prison sentence upon an accused who is unwilling expressly to admit his guilt but who, faced with grim alternatives, is willing to waive his trial and accept the sentence.” State v. Gardner, 2018 UT App 126 , ¶ 9 n.5, 428 P.3d 58 (quoting North Carolina v. Alford, 400 U.S. 25 , 35–36 (1970)); see also State v. Ott, 2010 UT 1 , ¶ 9 n

2019An Alford plea is a type of guilty plea in which “a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” These pleas allow courts to impose “a prison sentence upon an accused who is unwilling expressly to admit his guilt but who, faced with grim alternatives, is willing to waive his trial and accept the sentence.” State v. Gardner, 2018 UT App 126 , ¶ 9 n.5, 428 P.3d 58 (quoting North Carolina v. Alford, 400 U.S. 25 , 35–36 (1970)); see also State v. Ott, 2010 UT 1 , ¶ 9 n

24
State v. Archuletagreen
utahctapp · 2019 · cited in 3 Utah opinions naming this issue, 2019–2023
2 sentences

2019“An Alford plea is a type of guilty plea in which a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” State v. Archuleta, 2019 UT App 136 , ¶ 5 n.2, 449 P.3d 223 (quotation simplified).

2019“An Alford plea is a type of guilty plea in which a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” State v. Archuleta, 2019 UT App 136 , ¶ 5 n.2, 449 P.3d 223 (quotation simplified).

13
United States v. Buonocoregreen
ca10 · 2005 · cited in 1 Utah opinions naming this issue, 2014–2014
2 sentences

2014Rather, the defendant enters a guilty plea because he recognizes that a prosecutor has enough evidence to obtain a guilty verdict.” State v. Ott, 2010 UT 1 , ¶ 9 n. 2, 247 P.3d 344 (citing North Carolina v. Alford, 400 U.S. 25, 28, 37 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970)); see also United States v. Buonocore, 416 F.3d 1124, 1129 (10th Cir.2005) (explaining that an Alford plea is a guilty plea "accompanied by protestations of innocence” and can be accepted by a court "when there is a strong factual basis for the plea,” similar to a plea of nolo contendere (citing Alford, 400 U.S. at 28-29, 38

2014Rather, the defendant enters a guilty plea because he recognizes that a prosecutor has enough evidence to obtain a guilty verdict.” State v. Ott, 2010 UT 1 , ¶ 9 n. 2, 247 P.3d 344 (citing North Carolina v. Alford, 400 U.S. 25, 28, 37 , 91 S.Ct. 160 , 27 L.Ed.2d 162 (1970)); see also United States v. Buonocore, 416 F.3d 1124, 1129 (10th Cir.2005) (explaining that an Alford plea is a guilty plea "accompanied by protestations of innocence” and can be accepted by a court "when there is a strong factual basis for the plea,” similar to a plea of nolo contendere (citing Alford, 400 U.S. at 28-29, 38

11
Alford v. TUDOR HALL AND ASSOCIATES, INC.green
ncctapp · 1985 · cited in 1 Utah opinions naming this issue, 2004–2004
2 sentences

2004Id. ¶ 22 The Alford standard would ask us to determine whether Albrecht “acknowledged an obligation to secure a policy,” thereby creating a duty to procure insurance.

2004Id. ¶ 22 The Alford standard would ask us to determine whether Albrecht “acknowledged an obligation to secure a policy,” thereby creating a duty to procure insurance.

11
State v. Ostlergreen
utahctapp · 2000 · cited in 1 Utah opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., State v. Ostler, 2000 UT App 28 ,% 17, 996 P.2d 1065 , aff'd on other grounds, 2001 UT 68 , 31 P.3d 528 ; State v. Stilling, 856 P.2d 666, 674-75 (Utah Ct.App.1993) (addressing rule 11 in the context of an Alford plea).

2003See, e.g., State v. Ostler, 2000 UT App 28 ,% 17, 996 P.2d 1065 , aff'd on other grounds, 2001 UT 68 , 31 P.3d 528 ; State v. Stilling, 856 P.2d 666, 674-75 (Utah Ct.App.1993) (addressing rule 11 in the context of an Alford plea).

11
State v. Ostlergreen
utah · 2001 · cited in 1 Utah opinions naming this issue, 2003–2003
2 sentences

2003See, e.g., State v. Ostler, 2000 UT App 28 ,% 17, 996 P.2d 1065 , aff'd on other grounds, 2001 UT 68 , 31 P.3d 528 ; State v. Stilling, 856 P.2d 666, 674-75 (Utah Ct.App.1993) (addressing rule 11 in the context of an Alford plea).

2003See, e.g., State v. Ostler, 2000 UT App 28 ,% 17, 996 P.2d 1065 , aff'd on other grounds, 2001 UT 68 , 31 P.3d 528 ; State v. Stilling, 856 P.2d 666, 674-75 (Utah Ct.App.1993) (addressing rule 11 in the context of an Alford plea).

11
State v. Hamiltongreen
ariz · 1984 · cited in 1 Utah opinions naming this issue, 1993–1993
2 sentences

1993See also State v. Hamilton, 142 Ariz. 91 , 688 P.2d 983, 985 (1984) (factual basis for Alford plea can be established by "the record as a whole or any part of it, including a preliminary hearing").

1993See also State v. Hamilton, 142 Ariz. 91 , 688 P.2d 983, 985 (1984) (factual basis for Alford plea can be established by "the record as a whole or any part of it, including a preliminary hearing").

11
United States v. Paul Anthony Whitegreen
ca8 · 1984 · cited in 1 Utah opinions naming this issue, 1993–1993
2 sentences

1993United States v. White, 724 F.2d 714 (8th Cir.1984).

1993Id. at 716.

11
United States v. Thomas A. Owen and Jacqueline L. Owengreen
ca11 · 1988 · cited in 1 Utah opinions naming this issue, 1993–1993
2 sentences

1993In Alford plea cases, however, when a defendant necessarily does not admit to all elements of the charged crimes, the record must be sufficient to satisfy the trial court and/or a reviewing court that the State’s case is strong enough to warrant acceptance of the plea when guilt is not admitted by the defendant. 8 While the record as a whole need not be conclusive or uncontroverted on the question of guilt, “there must be evidence from which a court could reasonably find that the defendant was guilty — a factual basis for the plea.” United States v. Owen, 858 F.2d 1514, 1517 (11th Cir. 1988).

1993In Alford plea cases, however, when a defendant necessarily does not admit to all elements of the charged crimes, the record must be sufficient to satisfy the trial court and/or a reviewing court that the State's case is strong enough to warrant acceptance of the plea when guilt is not admitted by the defendant. [8] While the record as a whole need not be conclusive or uncontroverted on the question of guilt, "there must be evidence from which a court could reasonably find that the defendant was guilty — a factual basis for the plea." United States v. Owen, 858 F.2d 1514, 1517 (11th Cir. 1988)

11
State v. Kinggreen
arizctapp · 1977 · cited in 1 Utah opinions naming this issue, 1993–1993
2 sentences

1993Id. at 263 (citing State v. King, 116 Ariz. 353 , 569 P.2d 295, 297 (App.1977) ("factual basis for Alford plea was established by prosecutor's recitation of the state's case").

1993Id. at 263 (citing State v. King, 116 Ariz. 353 , 569 P.2d 295, 297 (App.1977) ("factual basis for Alford plea was established by prosecutor's recitation of the state's case").

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Utah. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
State v. Walton green
utahctapp · 2019
2 sentences

2023An “Alford plea is a type of guilty plea in which a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” State v. Walton, 2019 UT App 187 , ¶ 1 n.1, 455 P.3d 1066 (quotation simplified).

2023An “Alford plea is a type of guilty plea in which a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” State v. Walton, 2019 UT App 187 , ¶ 1 n.1, 455 P.3d 1066 (quotation simplified).

22019–2023
State v. Edwards green
utahctapp · 2023
1 sentence

2023But at the change of plea hearing and in the written minutes, the district court chose to accept the plea as being a “no (continued…) 20210063-CA 2 2023 UT App 23 State v. Edwards ¶5 The district court initially scheduled a sentencing hearing for April 2020, but the court later pushed sentencing back to August 31, 2020, due to the COVID-19 outbreak.

12023–2023
State v. Jessop green
utahctapp · 2023
1 sentence

2023An Alford plea is a type of guilty plea in which a defendant does not expressly admit his guilt, but nonetheless (continued…) 20210544-CA 13 2023 UT App 140 State v. Jessop against a peace officer.

12023–2023
State v. Gardner green
utahctapp · 2018
2 sentences

2019An Alford plea is a type of guilty plea in which “a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” These pleas allow courts to impose “a prison sentence upon an accused who is unwilling expressly to admit his guilt but who, faced with grim alternatives, is willing to waive his trial and accept the sentence.” State v. Gardner, 2018 UT App 126 , ¶ 9 n.5, 428 P.3d 58 (quoting North Carolina v. Alford, 400 U.S. 25 , 35–36 (1970)); see also State v. Ott, 2010 UT 1 , ¶ 9 n

2019An Alford plea is a type of guilty plea in which “a defendant does not expressly admit his guilt, but nonetheless waives his right to a trial and authorizes the court for purposes of the case to treat him as if he were guilty.” These pleas allow courts to impose “a prison sentence upon an accused who is unwilling expressly to admit his guilt but who, faced with grim alternatives, is willing to waive his trial and accept the sentence.” State v. Gardner, 2018 UT App 126 , ¶ 9 n.5, 428 P.3d 58 (quoting North Carolina v. Alford, 400 U.S. 25 , 35–36 (1970)); see also State v. Ott, 2010 UT 1 , ¶ 9 n

12019–2019
State v. Alzaga green
utahctapp · 2015
2 sentences

2018State v. Algaza , 2015 UT App 133 , ¶ 40, 352 P.3d 107 (explaining that when a defendant does not preserve claims before the district court, the defendant "must establish plain error, ineffective assistance of counsel, or exceptional circumstances to warrant [appellate] review" (quotation simplified) ).

2018State v. Algaza , 2015 UT App 133 , ¶ 40, 352 P.3d 107 (explaining that when a defendant does not preserve claims before the district court, the defendant "must establish plain error, ineffective assistance of counsel, or exceptional circumstances to warrant [appellate] review" (quotation simplified) ).

12018–2018
State v. Gutierrez green
utahctapp · 1993
1 sentence

2018"When a [district] court bases its ultimate conclusions concerning the waiver of [a] defendant's Miranda rights, upon essentially undisputed facts, in particular the transcript of an officer's colloquy with [the] defendant, its conclusions present questions of law which we review under a correction of error standard." State v. Gutierrez , 864 P.2d 894 , 898 (Utah Ct. App. 1993) (quotation simplified). ¶12 Gardner also contends the district court exceeded its discretion when it rejected "the plea agreement reached by the parties." Gardner asserts that this issue was preserved below when the cou

12018–2018
State v. Draper green
ariz · 1989
2 sentences

1993Id. at 263 (citing State v. King, 116 Ariz. 353 , 569 P.2d 295, 297 (App.1977) (“factual basis for Alford plea was established by prosecutor’s recitation of the state’s case”).

1993Id. at 263 (citing State v. King, 116 Ariz. 353 , 569 P.2d 295, 297 (App.1977) ("factual basis for Alford plea was established by prosecutor's recitation of the state's case").

11993–1993

Statutes the citing opinions construe

UT § Utah Code § 77-13-6 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 265 (1977–2025) CT 262 (1980–2026) OH 241 (1990–2026) IA 182 (1979–2026) WA 123 (1987–2026) LA 90 (1988–2025) MO 87 (1983–2025) MN 75 (1989–2026) WI 75 (1981–2026) MD 67 (1981–2026) VA 61 (1995–2025) ID 59 (1975–2026) TN 56 (1991–2026) GA 53 (1988–2026) KY 53 (1985–2026) NC 51 (1992–2026) MS 36 (2005–2024) MT 35 (1992–2026) IL 33 (1987–2026) KS 32 (1980–2026) PA 25 (1984–2025) SC 23 (2005–2024) WV 20 (1996–2024) ND 18 (1982–2025) CO 18 (1982–2025) MA 17 (1984–2025) CA 17 (1989–2025) NM 16 (1996–2024) WY 15 (1992–2026) OR 14 (1973–2026) UT 13 (1993–2023) AZ 12 (1977–2017) NV 12 (1994–2020) OK 11 (2006–2020) FL 11 (1989–2025) RI 11 (1992–2019) TX 10 (1974–2025) DC 9 (1977–2024) SD 9 (1995–2019) IN 5 (1986–2005) AR 5 (2006–2024) VT 5 (1993–2021) NE 3 (2006–2024) NJ 2 (1994–2025) VI 2 (1982–2026) NH 2 (1995–1995) AK 2 (1982–1982)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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