Term: 2011
Docket: 10-209
Blaine Lafler, Petitioner v. Anthony Cooper
- Pro
10-209 LAFLER V. COOPER DECISION BELOW: 376 Fed.Appx. 563 IN ADDITION TO THE QUESTIONS PRESENTED BY THE PETITIONS THE PARTIES ARE DIRECTED TO BRIEF AND ARGUE THE FOLLOWING QUESTION: "WHAT REMEDY, IF ANY, SHOULD BE PROVIDED FOR INEFFECTIVE ASSISTANCE OF COUNSEL DURING PLEA BARGAIN NEGOTIATIONS IF THE DEFENDANT WAS LATER CONVICTED AND SENTENCED PURSUANT TO CONSTITUTIONALLY ADEQUATE PROCEDURES?" CERT. GRANTED 1/7/2011 QUESTION PRESENTED: Anthony Cooper faced assault with intent to murder charges. His counsel advised him to reject a plea offer based on a misunderstanding of Michigan law. Cooper rejected the offer, and he was convicted as charged. Cooper does not assert that any error occurred at the trial. On habeas review, the Sixth Circuit found that because there is a reasonable probability that Cooper would have accepted the plea offer had he been adequately advised, his Sixth Amendment rights were violated. The writ was conditioned on Michigan re-offering the plea agreement. The question presented is: Is a state habeas petitioner entitled to relief where his counsel deficiently advises him to reject a favorable plea bargain but the defendant is later convicted and sentenced pursuant to a fair trial? LOWER COURT CASE NUMBER: 09-1487
In the case of Blaine Lafler v. Anthony Cooper, 2011, the U.S. Supreme Court ruled that a defendant's Sixth Amendment right to effective assistance of counsel is violated when their attorney gives them incorrect advice leading to rejection of a plea deal and proceeding to trial instead. The petitioner, Anthony Cooper was charged with assault with intent to murder and three other offenses in Michigan state court. His lawyer advised him incorrectly about the law which led him to reject a favorable plea offer from prosecution and go for trial where he was convicted on all charges and received a harsher sentence than what had been offered in the plea deal. The Supreme Court held that even if his conviction after fair trial was valid, he could still claim ineffective assistance of counsel during pretrial negotiations causing loss of any substantive or procedural benefit that would have resulted from acceptance of proposed plea bargain.
In the dissenting opinion for Blaine Lafler v. Anthony Cooper, Justice Scalia argued that the majority's decision expanded the Sixth Amendment beyond its original intent. He contended that it was not designed to ensure a fair trial outcome but rather to protect defendants from corrupt or overzealous prosecutors and incompetent counsel during plea bargaining. Scalia believed that while ineffective assistance of counsel could be grounds for setting aside a guilty verdict, it should not apply in cases where defendants rejected plea deals based on bad advice since they still received a fair trial afterward. He also criticized the majority's remedy as impractical and unworkable because it would require judges to speculate about what might have happened had different legal advice been given.
