Lafler v. Cooper
132 S. Ct. 1376
| SCOTUS | 2012Background
- Respondent shot Mundy and fled; Mundy survived after being shot in multiple places.
- Respondent was charged with numerous offenses including assault with intent to murder and firearm offenses; two pretrial plea offers to dismiss charges for a sentence were made but rejected.
- Respondent admitted guilt in communications but rejected offers after his attorney advised he could not be convicted at trial; later a less favorable plea offer was rejected on the first day of trial.
- After trial, respondent was convicted on all counts and sentenced to 185 to 360 months under a mandatory minimum.
- Ginther hearing occurred; state court rejected ineffective-assistance claim; federal habeas relief granted by district court; Sixth Circuit affirmed, reversing on Strickland grounds; Court granted certiorari.
- Court addresses whether ineffective-assistance during plea negotiations can justify relief when rejection of a plea leads to trial and a harsher sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Strickland prejudice applies when counsel’s ineffective advice causes rejection of a plea | Cooper argues rejection of plea due to bad advice caused prejudice | State argues prejudice requires different outcomes only if plea would have been offered/accepted | Yes; prejudice shown by likelihood of plea offer and lesser sentence if accepted |
| Extent of Sixth Amendment right in plea negotiations | Cooper contends plea-bargaining rights extend to rejecting offers | State contends right is not about rejecting offers but overall trial fairness | Right applies to plea negotiations; pretrial counsel conduct can cause prejudice regardless of trial outcome |
| Remedy for ineffective assistance in plea bargaining | Cooper seeks specific performance of the original plea | State opposes windfall remedies and prefers tailored relief | Remedy should be reoffering the plea; court discretion to vacate convictions or resentence consistent with the plea terms |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-part test for ineffective assistance of counsel)
- Hill v. Lockhart, 474 U.S. 52 (1985) (applies Strickland to guilty-plea challenges; prejudice test focuses on plea outcome)
- Padilla v. Kentucky, 559 U.S. 356 (2010) (requires competent counsel during plea negotiations (including if plea rejected))
- Glover v. United States, 531 U.S. 198 (2001) (ineffective assistance during sentencing can be prejudicial)
- Kimmelman v. Morrison, 477 U.S. 365 (1986) (counsel's failure to file timely motions can be prejudice; preserves right to habeas relief)
- United States v. Mechanik, 475 U.S. 66 (1986) (reversal not required for trial errors that are cured; context matters for prejudice)
- Vasquez v. Hillery, 474 U.S. 254 (1986) (structural errors vs. harmless errors; prejudice analysis)
- Williams v. Taylor, 529 U.S. 362 (2000) (clarifies Strickland prejudice standard remains intact)
- Premo v. Moore, 562 U.S. 115 (2011) (AEDPA review; guards against independent state-law errors under Strickland)