People of Michigan v. Juan T Walker, 332491

In 2001 Walker was convicted of first-degree premeditated murder (life without parole) and felony-firearm; convictions were previously affirmed and cert. denied.
In 2011 Walker moved for relief after discovering his trial counsel had not informed him of a prosecutor’s plea offer to second-degree murder (25–50 years) plus two years for felony-firearm.
The Michigan Supreme Court remanded for a Ginther evidentiary hearing to test an ineffective-assistance claim under Strickland and the Lafler/Frye framework.
At the Ginther hearing the trial court found counsel deficient for failing to convey the offer, and later granted relief, ordering the prosecution to reoffer the plea; Walker pleaded guilty and was resentenced per the offer.
On appeal the prosecution challenged the prejudice element — specifically that Walker failed to show a reasonable probability he would have accepted the plea given his consistent claims of innocence.
The Court of Appeals reversed the trial court, holding the trial court clearly erred and abused its discretion by finding prejudice without adequate, case-specific findings that Walker would have accepted the plea.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Walker)	Held
Whether Walker received ineffective assistance because counsel failed to convey the plea offer	Trial court erred to the extent it overlooked credibility issues; but prosecution concedes counsel likely failed to convey offer (focus on prejudice)	Counsel failed to inform Walker of the plea offer, satisfying deficient-performance prong	Trial court did not clearly err finding counsel deficient; that prong stands (not the central dispute on appeal)
Whether Walker was prejudiced — reasonable probability he would have accepted the plea	Walker’s expressed innocence and inconsistent testimony show he would not likely have accepted the plea; thus no prejudice	Walker would have accepted plea to avoid life without parole; his later acceptance supports prejudice	Reversed: trial court clearly erred and abused discretion in finding prejudice because it failed to make case-specific findings that Walker would have accepted the plea

Lafler v. Cooper, 566 U.S. 156 (2012) (prejudice test and remedy when counsel’s errors cause loss of a plea offer)
Missouri v. Frye, 566 U.S. 134 (2012) (defendant must show reasonable probability he would have accepted offer not conveyed)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance standard)
People v. Douglas, 496 Mich. 557 (2014) (defendant’s professed innocence can undercut claim he would have accepted a plea)
People v. Carbin, 463 Mich. 590 (2001) (Michigan articulation of Strickland standard)