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Keywords

defendantattorneyappealtrialpleahabeas corpuswillfelonymisdemeanorplea bargainrespondentguilty plea
defendantattorneyappealtrialpleahabeas corpuswillfelonymisdemeanorplea bargainrespondentguilty plea

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Lafler v. Cooper

Facts

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. In any event the shot missed and Mundy fled. Respondent followed in pursuit, firing repeatedly. Mundy was shot in her buttock, hip, and abdomen but survived the assault. Respondent was charged under Michigan law with assault with intent to murder, possession of a firearm by a felon, possession of a firearm in the commission of a felony, misdemeanor possession of marijuana, and for being a habitual offender. On two occasions, the prosecution offered to dismiss some of the charges and to recommend a sentence of 51 to 85 months for the remaining charges, in exchange for a guilty plea. In a communication with the court respondent admitted guilt and expressed a willingness to accept the offer. Respondent, however, later rejected the offer on both occasions, allegedly after his attorney convinced him that the prosecution would be unable to establish his intent to murder Mundy because she had been shot below the waist. On the first day of trial the prosecution offered a significantly less favorable plea deal, which respondent again rejected. After trial, respondent was convicted on all counts and received a mandatory minimum sentence of 185 to 360 months' imprisonment.

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. In any event the shot missed and Mundy fled. Respondent followed in pursuit, firing repeatedly. Mundy was shot in her buttock, hip, and abdomen but survived the assault. Respondent was charged under Michigan law with assault with intent to murder, possession of a firearm by a felon, possession of a firearm in the commission of a felony, misdemeanor possession of marijuana, and for being a habitual offender. On two occasions, the prosecution offered to dismiss some of the charges and to recommend a sentence of 51 to 85 months for the remaining charges, in exchange for a guilty plea. In a communication with the court respondent admitted guilt and expressed a willingness to accept the offer. Respondent, however, later rejected the offer on both occasions, allegedly after his attorney convinced him that the prosecution would be unable to establish his intent to murder Mundy because she had been shot below the waist. On the first day of trial the prosecution offered a significantly less favorable plea deal, which respondent again rejected. After trial, respondent was convicted on all counts and received a mandatory minimum sentence of 185 to 360 months' imprisonment.

Issue

The question for this Court is how to apply Strickland's prejudice test where ineffective assistance results in a rejection of the plea offer and the defendant is convicted at the ensuing trial.

The question for this Court is how to apply Strickland's prejudice test where ineffective assistance results in a rejection of the plea offer and the defendant is convicted at the ensuing trial.

Rule

To establish Strickland prejudice, a defendant must 'show that there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different.' In the context of pleas a defendant must show the outcome of the plea process would have been different with competent advice.

To establish Strickland prejudice, a defendant must 'show that there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different.' In the context of pleas a defendant must show the outcome of the plea process would have been different with competent advice.

Analysis

In this case, the Court of Appeals for the Sixth Circuit agreed with the test for Strickland prejudice in the context of a rejected plea bargain. The court found that respondent's attorney had provided deficient performance by informing respondent of 'an incorrect legal rule,' and that respondent suffered prejudice because he 'lost out on an opportunity to plead guilty and receive the lower sentence that was offered to him.' The court held that the right to effective assistance of counsel extends to the plea-bargaining process, and that the failure to provide competent legal advice regarding the plea offer resulted in a significant disadvantage for the defendant.

In this case, the Court of Appeals for the Sixth Circuit agreed with the test for Strickland prejudice in the context of a rejected plea bargain. The court found that respondent's attorney had provided deficient performance by informing respondent of 'an incorrect legal rule,' and that respondent suffered prejudice because he 'lost out on an opportunity to plead guilty and receive the lower sentence that was offered to him.' The court held that the right to effective assistance of counsel extends to the plea-bargaining process, and that the failure to provide competent legal advice regarding the plea offer resulted in a significant disadvantage for the defendant.

Conclusion

The judgment upholding the grant of the writ of habeas corpus and directing that the plea bargain be enforced was vacated, and the case was remanded for remedial action.

The judgment upholding the grant of the writ of habeas corpus and directing that the plea bargain be enforced was vacated, and the case was remanded for remedial action.

Who won?

The respondent, Cooper, prevailed in the case because the Supreme Court recognized that he suffered prejudice from his counsel's ineffective assistance, which led to the rejection of a favorable plea offer.

The respondent, Cooper, prevailed in the case because the Supreme Court recognized that he suffered prejudice from his counsel's ineffective assistance, which led to the rejection of a favorable plea offer.

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