State v. Smith

The issue presented in this case is whether a defendant, as part of a plea agreement with the State, can enter an Alford 1 plea to a crime which was legally impossible for the defendant to have committed. We hold that in order to accept an Alford plea, even in the context of a plea agreement, a court must find that there is strong proof of guilt as to each element of the crime to which the defendant is pleading. Since it was legally impossible in this case for the defendant to have committed the crime to which he entered an Alford plea, the trial court could not have found strong proof of…