United States v. Williams

An Alford plea to a state charge does not provide sufficient evidence “to prove commission of a state crime for purposes of a federal supervised release violation” when the state does not treat the plea as “sufficiently probative of the fact that the defendant actually committed the acts constituting the crime or crimes of conviction.”

Defendant Kenneth Maynard Williams pled guilty in 2009 to receiving a stolen motorcycle, a federal crime, and was sentenced to 15 months in prison and three years of supervised release. "While on supervised release, Williams was charged under Washington state law with second-degree assault with a firearm and unlawful possession of a firearm." Williams maintained his innocence, but on August 22, 2012, Williams entered an Alford plea to a single assault charge because he believed that he ran "a substantial risk of being convicted if the [j]ury believed the state[']s [e]evidence." As a result of the Alford plea, Williams was charged with violating the terms of his supervised release, which required that he “shall not commit another federal, state or local crime.” The district court found that Williams had violated his supervised release and sentenced Williams to 18 months in prison. On appeal, the Ninth Circuit reviewed whether "an Alford plea entered in Washington is legally sufficient by itself to warrant a finding that a person on supervised release violated the prohibition against committing a new state crime...." The panel, giving weight to the fact that Washington law does not treat an Alford plea as "sufficiently probative of the fact that the defendant actually committed the acts," held that "an Alford plea is insufficient evidence to prove commission of a state crime for purposes of a federal supervised release violation." REVERSED, VACATED, and REMANDED.