In the Matter of C.L., 217 N.C. App. 109 (2011)


The trial court did not err in accepting the juvenile’s Alford admission where the court adequately advised the juvenile of the consequences of his Alford admission and the juvenile made an informed choice to admit responsibility. After noting that G.S. 7B-2405(6) affords juveniles “all rights afforded adult offenders” except those then mentioned in the Juvenile Code, the Court of Appeals evaluated the trial court’s actions pursuant to G.S. 15A-1022, relating to guilty pleas in superior court, rather than under G.S. 7B-2407, the Juvenile Code provision for accepting a juvenile’s admission. The court held that the trial court basically complied with G.S. 15A-1022 and had not erred in accepting the juvenile’s Alford admission. Contrary to the “strict compliance” rule that applies to the acceptance of a juvenile’s admission under G.S. 7B-2407(a), the Court of Appeals held that the “totality of the circumstances” test applies to determine “whether [the trial court’s failure to make the inquiry specified in N.C. Gen. Stat. § 15A-1022(d)] either affected [Juvenile’s] decision to plead or undermined the plea’s validity.”

Alford Admission
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