| Lafler v. Cooper | |
|---|---|
 | |
| Argued October 31, 2011 Decided March 21, 2012 | |
| Full case name | Blaine Lafler, Petitioner v. Anthony Cooper, Respondent |
| Docket no. | 10-209 |
| Citations | 566 U.S. 156 (more) 132 S. Ct. 1376; 182 L. Ed. 2d 398 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | Habeas corpus granted, Cooper v. Lafler, No. 06–11068, 2009 WL 817712 (E.D. Mich., March 26, 2009); aff'd, 376 F. App'x 563 (6th Cir. 2010); cert. granted sub nom. Lafler v. Cooper, 562 U.S. 1127 (2011). |
| Holding | |
| In cases of ineffective assistance of counsel leading to the rejection of a plea agreement, in order to show prejudice under Strickland v. Washington, a defendant must show that but for the ineffective advice, there is a reasonable probability that the plea offer would have been presented to the court, that the court would have accepted its terms, and that the conviction or sentence, or both, under the offer’s terms would have been less severe than under the actual judgment and sentence imposed. Relief in such cases should be tailored to the specific circumstances of each case. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Kennedy, joined by Ginsburg, Breyer, Sotomayor, Kagan |
| Dissent | Scalia, joined by Thomas; Roberts (all but Part IV) |
| Dissent | Alito |
Lafler v. Cooper, 566 U.S. 156 (2012), was a United States Supreme Court case in which the Court clarified the Sixth Amendment standard for reversing convictions due to ineffective assistance of counsel during plea bargaining. The Court ruled that when a lawyer's ineffective assistance leads to the rejection of a plea agreement, a defendant is entitled to relief if the outcome of the plea process would have been different with competent advice. In such cases, the Court ruled that the Sixth Amendment requires the trial judge to exercise discretion to determine an appropriate remedy.
Anthony Cooper was charged by the State of Michigan with assault with intent to murder and three other offenses. After being incorrectly advised by his lawyer that the prosecution would be unable to prove intent to murder, he rejected a plea bargain. After being convicted at a fair trial, he appealed his conviction, arguing that his lawyer had provided ineffective assistance of counsel by advising him to reject the plea deal. Michigan courts denied him relief, but federal courts granted a writ of habeas corpus requiring the State to reduce Cooper's sentence to the one he would have received under the plea agreement. The State appealed to the Supreme Court, which agreed to hear the case.
Writing for the 5–4 majority, Justice Kennedy ruled that ineffective assistance of counsel during plea negotiations can constitute grounds for relief if there is a fair probability that defense counsel's ineffective assistance resulted in a harsher sentence or conviction. In those cases, Justice Kennedy wrote, trial judges should exercise discretion in choosing to vacate a conviction and accept the original plea bargain, resentence the defendant, or leave the original conviction undisturbed. Justice Scalia wrote a dissenting opinion joined by Justice Thomas and Chief Justice Roberts (in large part) which argued that the majority had invented a constitutional right to plea bargain. Justice Alito also wrote a dissenting opinion in which he largely agreed with Justice Scalia and specifically argued that the majority's remedy was unsound.
Reactions following the Supreme Court's ruling were mixed, with some commentators praising the Court's recognition of the role of plea bargaining in criminal justice and others criticizing the implications of not sufficiently protecting defendants' rights and of requiring defense counsel to plea bargain at the desire of the prosecutor.