Jeffrey Dane Murray v. State, 156 Idaho 159

Murray pled guilty to felony domestic violence after plea negotiations with counsel, Martens, which included dismissal of related charges and a recommended sentence of three years fixed and seven years indeterminate.
The court required a Guilty Plea Advisory Form referencing Estrada rights and obtained a written waiver of those rights, with Murray initialing acknowledgment.
Murray underwent a domestic violence evaluation and a presentence report influencing sentencing; the court imposed ten years in prison with three years fixed.
Murray did not appeal his sentence but later filed a petition for post-conviction relief alleging ineffective assistance of counsel and other defects in the plea process.
The district court dismissed Murray’s petition after finding no preponderance of evidence showing deficient performance or prejudice; Murray appealed.
This Court affirmed the district court’s dismissal, holding no ineffective assistance and denying relief; costs awarded to the State.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Martens’ failure to advise Estrada rights was ineffective assistance.	Murray argues Martens failed to inform him of Estrada rights, causing prejudice.	Martens complied with Estrada-related advisements as the court had informed Murray of those rights.	No reversible prejudice; failure to advise did not prejudice Murray.
Whether Martens’ failure to advise about a confidential domestic violence evaluation was ineffective.	Murray contends failure to advise about confidential evaluation before pleading was deficient.	No authority requiring counsel to advise about confidential evaluations pre-plea.	Waived; Murray lacked authority indicating error clear enough to grant relief.
Whether the district court properly dismissed the post-conviction petition.	District court erred in applying Strickland and Gonzales to dismissal.	District court properly applied Strickland standard and Gonzales to deny relief.	Affirmed; petition properly dismissed.

Estrada v. State, 143 Idaho 558 (2006) (right to counsel before psychosexual evaluation and Fifth Amendment implications)
Gonzales v. State, 151 Idaho 168 (2010) (right to Estrada advice before evaluation; reading advisory court suffices in some contexts)
Booth v. State, 151 Idaho 612 (2011) (two-prong Strickland test for plea-stage ineffective assistance)
Ridgley v. State, 148 Idaho 671 (2010) (reasonable probability standard for prejudice in plea context)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes deficient performance and prejudice prongs)
United States v. Wade, 388 U.S. 218 (1967) (right to counsel at critical stages)
Benlian, 63 F.3d 824 (9th Cir. 1995) (relevance of stage-based counsel rights)