Lafler v. Cooper
Citation
566 U.S. 156 (2012)
Facts
Defense counsel incorrectly advised Cooper that the prosecution could not prove intent to murder because the victim was shot below the waist; relying on this advice, Cooper rejected a favorable plea offer, was convicted at trial, and received a substantially heavier sentence than the offer would have carried.
Issue
Whether the Sixth Amendment right to effective assistance of counsel applies to the plea negotiation process, and if so, what remedy is available when deficient advice causes a defendant to reject a favorable plea.
Holding
The Court held the Sixth Amendment applies to plea negotiations and that Cooper was entitled to relief, with the proper remedy left to the trial court’s discretion.
Rule
Ineffective assistance during plea negotiations is cognizable under the Sixth Amendment; prejudice is shown where the defendant would have accepted the plea but for counsel’s deficient advice, the court would have accepted its terms, and the conviction or sentence was more severe than the plea would have provided.