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Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

attorneyappealtrialpleawillrespondentguilty plea
attorneytrialplearespondent

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Lafler v. Cooper, 566 U.S. 156, 132 S.Ct. 1376, 182 L.Ed.2d 398, 80 USLW 4244, 12 Cal. Daily Op. Serv. 3299, 2012 Daily Journal D.A.R. 3726, 23 Fla. L. Weekly Fed. S 203

Facts

The respondent was charged under Michigan law with assault with intent to murder and other offenses. The prosecution offered to dismiss some charges and recommend a 51-to-85-month sentence in exchange for a guilty plea. The respondent initially expressed a willingness to accept the offer but rejected it after his attorney advised him that the prosecution could not establish intent to murder. After going to trial, he was convicted on all counts and received a mandatory minimum sentence of 185 to 360 months. The state trial court and the Michigan Court of Appeals rejected his claim of ineffective assistance of counsel.

On the evening of March 25, 2003, respondent pointed a gun toward Kali Mundy's head and fired. From the record, it is unclear why respondent did this, and at trial it was suggested that he might have acted either in self-defense or in defense of another person.

Issue

Did the ineffective assistance of counsel in advising the petitioner to reject a plea offer result in a violation of his Sixth Amendment rights?

Did the ineffective assistance of counsel in advising the petitioner to reject a plea offer result in a violation of his Sixth Amendment rights?

Rule

The two-part Strickland v. Washington test applies to claims of ineffective assistance of counsel, requiring a showing of deficient performance and resulting prejudice.

The two-part Strickland v. Washington test applies to claims of ineffective assistance of counsel, requiring a showing of deficient performance and resulting prejudice.

Analysis

The court found that the respondent's attorney provided deficient performance by advising him incorrectly regarding the likelihood of conviction at trial. This led to the rejection of a favorable plea offer, resulting in a significantly harsher sentence after trial. The court applied the Strickland prejudice test, determining that there was a reasonable probability that the outcome of the plea process would have been different had the respondent received competent advice.

The court found that the respondent's attorney provided deficient performance by advising him incorrectly regarding the likelihood of conviction at trial.

Conclusion

The Supreme Court held that the petitioner was prejudiced by counsel's deficient performance and ordered the state to reoffer the plea agreement, allowing the trial court to exercise discretion regarding resentencing.

The Supreme Court held that the petitioner was prejudiced by counsel's deficient performance and ordered the state to reoffer the plea agreement.

Who won?

The petitioner prevailed because the Supreme Court found that he was prejudiced by ineffective assistance of counsel, which warranted a remedy that included reoffering the plea deal.

The petitioner prevailed because the Supreme Court found that he was prejudiced by ineffective assistance of counsel, which warranted a remedy that included reoffering the plea deal.

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