David Stiger v. Commonwealth of Kentucky, 381 S.W.3d 230

Stiger pled guilty in Jefferson Circuit Court to five counts of first-degree robbery in 2003; sentenced to concurrent 10-year terms, enhanced to 20 years as a first-degree persistent felon (PFO).
The violent-offender statute (KRS 439.3401) makes such offenders ineligible for parole until 85% of the sentence or 20 years, whichever is lesser.
Stiger moved under RCr 11.42 in January 2007 alleging involuntariness of the plea, ineffective assistance for misadvised parole expectations, and failure to respond to sentencing change; the trial court denied relief; Court of Appeals affirmed.
This Court granted discretionary review after Padilla v. Kentucky (2010) overruled its earlier Padilla ruling and addressed whether misadvice about parole and PFO effects could render a guilty plea invalid.
The Court held that (i) the record belies Stiger’s claim that he was unaware of the PFO sentence; (ii) the trial court was not obligated to inform him of parole consequences as direct; and (iii) although counsel’s misadvice about parole eligibility could be deficient under Padilla/Strickland, there was no prejudice to undermine the plea because trial outcome would unlikely improve at trial.
The Court ultimately affirmed the Court of Appeals’ decision denying relief under RCr 11.42.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stiger was informed about his PFO-enhanced sentence	Stiger relied on misadvice about parole and claimed surprise at PFO	Record shows plea agreement explicitly noted 20-year PFO enhancement	Record refutes claim; no involuntary plea on this basis.
Whether the trial court was obliged to advise about parole consequences	Parole ineligibility is a direct consequence of the plea (per Brady-like view)	Parole eligibility is not a direct consequence; court not required to advise	Not a direct consequence; failure to address does not render the plea involuntary.
Whether counsel's misadvice about parole eligibility prejudiced Stiger under Strickland/Padilla	Misadvice created deficient performance and prejudice	Even with misadvice, there is no reasonable probability of a better outcome at trial	No prejudice; no reasonable probability of a better result at trial; plea relief denied.

Padilla v. Kentucky, 559 U.S. __ (2010) (deficient performance when misadvice on immigration issues; rational plea analysis applies to collateral consequences)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes deficient performance and prejudice as prerequisites for ineffective assistance claims)
Brady v. United States, 397 U.S. 742 (1970) (due process voluntariness of guilty plea hinges on knowledge of direct consequences)
Harrington v. Richter, 131 S. Ct. 770 (2011) (prejudice standard for Strickland in the plea context; substantial likelihood required)
Premo v. Moore, 131 S. Ct. 733 (2011) (clarifies prejudice standard in guilty-plea ineffective assistance after Padilla)