EvidenceProf Blog

Editor: Colin Miller
Univ. of South Carolina School of Law

Wednesday, June 2, 2021

United States District Court for the District of Minnesota Deems Alford Plea Admissible

An Alford plea, based on the Supreme Court's opinion in North Carolina v. Alford, is a plea in which the defendant maintains her innocence but pleads guilty while acknowledging that the State has sufficient evidence to prove her guilt beyond a reasonable doubt. There's no federal (and, in most states, no state) rule of evidence governing the (in)admissibility of Alford pleas. So, what should courts do?

In a recent post, I discussed State Farm Mut. Auto. Ins. Co. v. Havemeier, 2021 WL 838768 (D.Minn. 2021), where the United States District Court for the District of Minnesota cited precedent holding that Alford pleas should be deemed inadmissible.

In State Farm Mutual Automobile Insurance Company v. Havemeier, 2021 WL 2188172 (D. Minn. 2021), however, a different judge on the same court ruled that

Havemeier's Alford plea and hearing transcript do not fall into any of the exclusions set forth in Rule 401(a). The plea was never withdrawn, and the plea and Havemeier's testimony during the Alford hearing do not constitute a statement made during plea discussions with an attorney for the prosecuting authority if the discussions did not result in a guilty plea or they resulted in a later-withdrawn guilty plea.



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