STATE OF NEW JERSEY VS. QUANTIS L. GOODE (07-10-3549, ESSEX COUNTY AND STATEWIDE), A-3508-19

Goode and co-defendant Davis were convicted by jury (2009) of two counts of first‑degree murder in a drug‑related, territorial shooting; Goode received an aggregate 100‑year term with 60 years parole ineligibility.
Before trial, defendants contend they were offered a plea to reckless manslaughter with a 14‑year sentence subject to the No Early Release Act (NERA); they allege trial counsel advised rejecting or mischaracterized plea consequences.
Defendants filed post‑conviction relief (PCR) petitions alleging ineffective assistance: counsel failed to explain sentencing exposure, mismanaged plea discussions, and incompletely prepared the Rule 3:9‑1(f) pretrial memorandum.
This court previously remanded for an evidentiary hearing to resolve credibility about whether a formal plea offer had been made and what counsel told defendants about consequences of proceeding to trial.
At the PCR hearing, prosecutor and defense counsel testified they recalled no formal plea offer; the trial court found their testimony and the court’s pretrial memorandum (showing no offer and noting life exposure) more credible than defendants’ testimony.
The PCR court denied relief, finding no deficient performance or prejudice (no plea offer was made; inaccuracies in the pretrial memorandum caused no prejudice), and the Appellate Division affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial counsel was ineffective for failing to convey a 14‑year plea offer	State: No formal plea offer was extended; counsel did not perform deficiently	Goode: Counsel told him of a 14‑year NERA offer and misadvised him, causing loss of plea	Held: No; judge credited prosecutor and counsel that no formal offer existed, so no prejudice under Strickland/Lafler
Whether counsel failed to complete or review the Rule 3:9‑1(f) pretrial memorandum	State: Pretrial memorandum errors existed but no plea offer was made so omission caused no harm	Goode: Errors omitted a murder count and failed to show consecutive life exposure; judge never reviewed on record	Held: No prejudice; even a correct memorandum would not have produced a plea offer or changed outcome
Whether omission of a pretrial conference denied due process	State: Rule errors are procedural and, if not raised earlier, are barred; no prejudice shown	Goode: Due process required the court to conduct/review the pretrial conference and inform him of true exposure	Held: Barred or meritless; Rule 3:22‑4(a) bars claim could have been raised on direct appeal; no substantive prejudice shown
Whether Lafler relief is available absent a formal plea offer	State: Lafler relief requires that a plea offer actually was made	Goode: Argues ineffective assistance in rejecting plea merits Lafler relief	Held: Lafler inapplicable—no plea offer was made, so claim fails

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong test for ineffective assistance of counsel)
Lafler v. Cooper, 566 U.S. 156 (prejudice from lost plea opportunity requires showing offer was made, would have been accepted, and result would have been less severe)
State v. Fritz, 105 N.J. 42 (adopts Strickland standard in New Jersey)
State v. Preciose, 129 N.J. 451 (preponderance of credible evidence standard in PCR proceedings)
State v. Nash, 212 N.J. 518 (deference to PCR court factual/credibility findings)
State v. Pierre, 223 N.J. 560 (review standards for PCR factual findings and credibility)
State v. Cottle, 194 N.J. 449 (right to effective assistance of counsel under state constitution)
State v. Norman, 151 N.J. 5 (discusses effective assistance principles in New Jersey)
State v. Moore, 273 N.J. Super. 118 (procedural bar to raising claims on PCR that could have been raised on direct appeal)