This form of guilty plea has been frequently used in local and state courts in the United States,[REF] though it constitutes a small percentage of all plea bargains in the U.S [REF].
In the 2006 case before the United States Court of Appeals for the Fifth Circuit, Ballard v. Burton, Judge Carl E. Stewart writing for the Court held that an Alford guilty plea is a "variation of an ordinary guilty plea" [REF].