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Keywords

pleafelonymisdemeanorprosecutorplea bargain

attorneyhearingtrialpleaarraignment

Related Cases

Missouri v. Frye, 566 U.S. 134, 132 S.Ct. 1399, 182 L.Ed.2d 379, 80 USLW 4253, 12 Cal. Daily Op. Serv. 3308, 2012 Daily Journal D.A.R. 3718, 23 Fla. L. Weekly Fed. S 198

Facts

Galin Frye was charged with driving with a revoked license, a felony due to prior convictions. The prosecutor offered two plea bargains, including a reduction to a misdemeanor with a recommended 90-day sentence. Frye's counsel did not inform him of these offers, which expired. Frye later pleaded guilty without a plea agreement and received a three-year sentence. He sought post-conviction relief, claiming ineffective assistance of counsel for not communicating the plea offers.

Frye's attorney did not advise Frye that the offers had been made. The offers expired. At the January 4 hearing, Frye waived his right to a preliminary hearing on the charge arising from the August 2007 arrest. He pleaded not guilty at a subsequent arraignment but then changed his plea to guilty. There was no underlying plea agreement.

Issue

Did Frye's counsel provide ineffective assistance by failing to communicate the prosecution's plea offers, thereby violating Frye's Sixth Amendment rights?

Did Frye's counsel's failure to communicate the prosecution's plea offers constitute ineffective assistance of counsel under the Sixth Amendment?

Rule

The Sixth Amendment right to effective assistance of counsel extends to the consideration of plea offers that lapse or are rejected. Defense counsel has a duty to communicate formal prosecution offers to accept a plea on favorable terms.

The Sixth Amendment right to effective assistance of counsel extends to the consideration of plea offers that lapse or are rejected.

Analysis

The court applied the Strickland two-part test for ineffective assistance of counsel, determining that Frye's counsel's failure to communicate the plea offers constituted deficient performance. The court found that Frye demonstrated prejudice, as he would have accepted the misdemeanor plea offer had he been informed. The court emphasized the importance of plea negotiations in the criminal justice system and the necessity for effective counsel during this critical stage.

The Missouri court correctly concluded that counsel's failure to inform Frye of the written plea offer before it expired fell below an objective reasonableness standard, but it failed to require Frye to show that the plea offer would have been adhered to by the prosecution and accepted by the trial court.

Conclusion

The Supreme Court held that Frye's counsel was ineffective for failing to communicate the plea offers, vacated the lower court's decision, and remanded the case for further proceedings.

Who won?

Galin Frye prevailed in the case because the court found that his counsel's failure to communicate the plea offers constituted ineffective assistance, violating his Sixth Amendment rights.

Frye met both of the requirements for showing a Sixth Amendment violation under Strickland. First, the court determined Frye's counsel's performance was deficient because the 'record is void of any evidence of any effort by trial counsel to communicate the Offer to Frye during the Offer window.'

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