Burt v. Titlow, 134 S. Ct. 10

State prisoner Titlow challenged a state-court conviction as ineffective assistance of counsel during plea bargaining.
District court denied relief under AEDPA's deferential review; Sixth Circuit reversed, applying a non-deferential analysis.
Michigan granted plea to manslaughter with a 7–15 year range; new counsel Toca negotiated but withdrew plea for a lower-minimum sentence dispute.
Titlow proclaimed innocence to counsel and trial strategy, leading to withdrawal of the plea and Billie Rogers’s acquittal; Titlow later stood trial and was convicted of second-degree murder.
On remand, prosecutors reoffered the original plea; Titlow, with updated counsel, could not provide a factual basis for the plea; court remanded for further proceedings; the Supreme Court granted certiorari.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Sixth Circuit erred in applying AEDPA and Strickland standards.	Titlow Argues Sixth Circuit misread factual findings and erred in deeming Toca ineffective.	Titlow's burden under AEDPA/Strickland approved state court's reasonable determinations.	Yes; Sixth Circuit erred; Michigan court's factual determinations reasonable.
Whether Toca provided ineffective assistance during plea withdrawal.	Titlow asserts Toca failed to adequately advise withdrawal given innocence claims.	Court held Toca's actions reasonable under the circumstances and presumptively effective.	No; approval of Toca's conduct and advice reasonable under Strickland and AEDPA.
Whether the record supports the Michigan Court of Appeals' conclusion about innocence proclamation.	Titlow's innocence assertion influenced withdrawal strategy.	Record shows innocence proclamation consistent with withdrawal rationale.	Supported; finding that withdrawal based on innocence was reasonable.
Whether the remedy fashioned by the Sixth Circuit was appropriate.	Remand to reoffer plea and fashion remedy.	Remedy not required where plea originally offered could not be renewed.	Remand remedy reversed; no need to decide broader Lafler issues.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (established standard of reasonable assistance and prejudice burden)
Florida v. Nixon, 543 U.S. 175 (U.S. 2004) (defendant has ultimate authority to decide plea with informed advice)
Lafler v. Cooper, 132 S. Ct. 1376 (S. Ct. 2012) (ineffective assistance where plea offer treated inequitably after misadvice)
Rice v. Collins, 546 U.S. 333 (U.S. 2006) (AEDPA requires deference to state-court factual determinations)
Estelle v. McGuire, 502 U.S. 62 (U.S. 1991) (federal habeas review of state-court factual findings; corroborating evidence not required)