Case law · Highest court · Federal

Lafler v. Cooper

Decided
March 21, 2012
Docket
10-209
Status
Published
Jurisdiction
Federal

Cited 3,280 timesNo negative treatment found in this library

What later courts said

  • concluding that Strickland analysis was “contrary to” clearly established law in part because the court’s analysis consisted of “irrelevant observation[s]” — Eric Mann v. Charles Ryan (2016)
  • holding that a defendant’s Sixth Amendment right to competent counsel extends to the plea-bargaining process — United States v. Santiago-Cordero (2017)
  • holding that a criminal defendant’s Sixth Amendment right to counsel “extends to the plea-bargaining process,” during which he or she is entitled to effective assistance of competent counsel — Alcorn v. State (2013)

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

[*160] Justice Kennedy delivered the opinion of the Court.

In this case, as in Missouri v. Frye, ante, p. 134, also decided today, a criminal defendant seeks a remedy when inadequate assistance of counsel caused nonacceptance of a plea offer and further proceedings led to a less favorable outcome. In Frye, defense counsel did not inform the defendant of the plea offer; and after the offer lapsed the defendant still pleaded guilty, but on more severe terms. Here, the favorable plea offer was reported to the client but, on advice of counsel, was rejected. In Frye, there was a later guilty plea. Here, after the plea offer had been rejected, there was a full and fair trial before a jury. After a guilty verdict, the defendant received a sentence harsher than that offered in the rejected plea bargain. The instant case comes to the Court with the concession that counsel’s advice with respect to the plea offer fell below the standard of adequate assistance of counsel guaranteed by the Sixth Amendment, applicable to the States through the Fourteenth Amendment.

I

Statutes cited

Cite this

Lafler v. Cooper, 566 U.S. 156 (2012)

Read the full opinion

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