Allanah Benton v. Shawn Brewer, 942 F.3d 305

Allanah Benton, a former teacher, was convicted by a Michigan jury of having sex with a 12‑year‑old and sentenced to 25–38 years' imprisonment.
After conviction and an unsuccessful direct appeal, the Supreme Court decided Lafler v. Cooper (2012), recognizing ineffective‑assistance claims where counsel's bad advice causes rejection of a favorable plea.
Benton filed a state postconviction motion alleging her trial counsel pressured her to reject a one‑year plea because he told her parental rights would be automatically terminated; she asserted she would have accepted the plea if told termination was not automatic.
Appellate counsel offered to stipulate to his own ineffectiveness to excuse Benton's failure to raise the claim on direct appeal; the state trial court denied relief on procedural (Mich. Ct. R. 6.508) and merits grounds, and higher state courts declined review.
Benton sought federal habeas relief; the district court denied it and the Sixth Circuit (with a COA) affirmed, holding Benton procedurally defaulted and failed to show cause to excuse the default.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural default—may federal court review Benton's ineffective‑assistance claim?	Benton: claim not raised on direct appeal because Lafler postdated the appeal and counsel was ineffective.	State: Benton failed to follow Mich. Ct. R. 6.508; state courts enforced rule; rule is adequate and independent.	Court: Claim is defaulted; state rule is an adequate and independent ground; federal review barred absent cause and prejudice.
Is Lafler's post‑decision novelty sufficient cause to excuse the default?	Benton: Lafler was decided after her direct appeal, so the legal basis was not reasonably available.	State: Lafler did not announce a novel rule—Sixth Circuit precedent already recognized such claims.	Court: Lafler was not so novel; novelty does not constitute cause.
Does appellate counsel’s stipulation of his own ineffectiveness establish cause?	Benton: appellate counsel offered to stipulate to his ineffectiveness, which should excuse the default.	State: A bare stipulation by counsel is insufficient proof that appellate counsel was ineffective for purposes of cause.	Court: Counsel’s self‑stipulation is threadbare and legally insufficient; Benton failed to show cause.

Lafler v. Cooper, 566 U.S. 156 (2012) (recognizes ineffective‑assistance claims when bad advice causes rejection of a favorable plea)
Magana v. Hofbauer, 263 F.3d 542 (6th Cir. 2001) (Sixth Circuit previously entertained claims that counsel's advice caused plea rejection)
Murray v. Carrier, 477 U.S. 478 (1986) (establishes counsel‑ineffectiveness as potential cause to excuse procedural default)
Reed v. Ross, 468 U.S. 1 (1984) (novelty of legal claim can sometimes establish cause, but the bar is high)
Engle v. Isaac, 456 U.S. 107 (1982) (discusses when legal tools to construct a claim were reasonably available)
Harrington v. Richter, 562 U.S. 86 (2011) (petitioner bears burden to prove ineffective assistance)
Maupin v. Smith, 785 F.2d 135 (6th Cir. 1986) (framework for procedural default and adequate independent state grounds)
Dufresne v. Palmer, 876 F.3d 248 (6th Cir. 2017) (Michigan procedural rule treated as adequate and independent ground)