Hudson v. Lashbrook
2017 U.S. App. LEXIS 12473
| 7th Cir. | 2017Background
- In 2005 Robert Hudson rejected plea offers (20 then 16 years) and went to trial on armed robbery and unlawful restraint charges; he was convicted.
- At sentencing counsel discovered an extensive violent criminal history, producing a mandatory natural life sentence without parole.
- Hudson filed federal habeas alleging ineffective assistance of counsel during plea negotiations; the district court granted relief under Lafler v. Cooper and ordered the State to reoffer the original 20-year plea.
- Illinois prosecutors reoffered a plea (15–30 years on attempted armed robbery) and Hudson accepted; the state trial judge refused to accept the plea, citing jurisdictional and state-law concerns and ultimately rejected the agreement on the merits; Hudson’s state appeal remains pending.
- Hudson returned to federal court seeking enforcement (immediate release); the district court denied relief, allowing the state appellate process to proceed; the Seventh Circuit affirmed dismissal for lack of jurisdiction because Hudson had already received the relief ordered by the federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a federal court must vacate a state sentence or force a state court to accept a reoffered plea after habeas relief under Lafler | Hudson: district court must enforce Lafler remedy (reoffer and effectuate plea) and grant relief if state court refuses | Illinois: district court’s remedy ends once state prosecutors reoffered the plea; state courts retain discretion to accept or reject pleas | Held: District court complied with Lafler by ordering reoffer; once State reoffered plea, federal court lost jurisdiction and cannot compel state judge to accept plea |
| Whether return to federal court after state judge rejects the plea is continuation of original habeas or a new petition | Hudson: seeks enforcement within same habeas proceeding | State: it's a new habeas matter because the state court issued a new ruling; must exhaust state remedies | Held: Treat as new claim; plaintiff must exhaust state appellate remedies before filing another habeas petition |
| Whether federal courts may order state officials to take actions that conflict with state law or bind state judges | Hudson: federal remedy required by Sixth Amendment may necessitate state action | State: federal courts cannot control state judges or force actions contrary to state law | Held: Federal habeas cannot commandeer state courts; the writ is limited and cannot force a state judge to accept an unlawful plea |
| Appropriate remedy under Lafler when plea is reoffered but rejected by state court | Hudson: seeks enforcement or release if state court refuses | State: trial court discretion governs whether to vacate convictions or accept plea; appellate review appropriate first | Held: Lafler requires reoffer; acceptance and sentencing decisions rest with state court discretion; federal court may enforce compliance but should allow state appellate process to resolve discretionary rulings |
Key Cases Cited
- Lafler v. Cooper, 566 U.S. 156 (2012) (establishes that ineffective assistance during plea negotiations can require the State to reoffer the plea as the proper remedy)
- Coulter v. McCann, 484 F.3d 459 (7th Cir. 2007) (a subsequent state-court ruling produces a new habeas claim rather than a mere continuation of the original petition)