Sunday, November 3, 2013

Lafler v. Coope case brief

Lafler v. Coope case brief summary
132 S.Ct. 1376 (2012)

Respondent state prison inmate rejected a plea bargain based on erroneous legal advice of counsel and was convicted at trial of all offenses and received a much greater sentence than offered in the plea bargain. Upon the grant of a writ of certiorari, petitioner prison warden appealed the judgment of the U.S. Court of Appeals for the Sixth Circuit which upheld a grant of a writ of habeas corpus based on ineffective assistance of counsel.

It was conceded that the inmate's counsel was deficient in providing erroneous legal advice concerning the plea bargain, but the warden contended that the inmate suffered no prejudice because the inmate was properly convicted after a fair trial.

The U.S. Supreme Court held that the inmate's fair trial did not preclude prejudice from counsel's ineffective assistance.

  • The right to effective assistance of counsel was not solely to ensure a fair trial, and there was no indication that the fair trial cured counsel's error. 
  • Further, the inmate suffered prejudice rather than a windfall based on the likelihood that the conclusion would have been different, since the inmate sought relief based on a failure to meet a valid legal standard rather than application of an incorrect legal principle. 
  • Also, a lack of prejudice could not be based on the reliability of the trial since the reliability of the pretrial bargaining, which caused the inmate to lose the benefits of the bargain, was the concern at issue. 
  • However, the appropriate remedy for counsel's error was to re-offer the plea bargain and conduct further proceedings in state court, rather than directing that the plea bargain be enforced.


The judgment upholding the grant of the writ of habeas corpus and directing that the plea bargain be enforced was vacated, and the case was remanded for remedial action. 5-4 Decision; 2 Dissents.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

No comments:

Post a Comment

The Evolution of Legal Marketing: From Billboards to Digital Leads Over the last couple of decades, the face of legal marketing has changed a l...