Lafler v. Cooper
Issues
Whether a defendant is entitled to habeas relief when that defendant received constitutionally defective advice from counsel during plea bargain negotiations, subsequently rejected a plea offer based on that defective advice, and ultimately was convicted and sentenced to a more severe sentence after a fair trial.
In 2003, Respondent Anthony Cooper faced trial for assault with intent to murder. Prosecutors offered Cooper two plea deals carrying lesser sentences than he would have received under the sentencing guidelines. Pursuant to the advice of his trial counsel, Cooper rejected both offers and received a sentence demonstrably longer than either plea offer. Cooper claims that the Sixth Amendment guarantees effective assistance of counsel at all critical stages of a criminal proceeding, including the plea bargaining process. Cooper argues that his trial counsel’s ineffective assistance prejudiced his trial, and that he is entitled to reinstatement of the plea offer. Petitioner Blaine Lafler argues that rejection of a plea bargain is not a critical stage. Lafler contends that Cooper is not entitled to relief because Cooper received a fair trial and no Sixth Amendment violation occurred. This case will determine the availability of habeas relief to a defendant who may have received constitutionally defective advice from counsel during plea bargaining negotiations.
Questions as Framed for the Court by the Parties
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?
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?
On March 25, 2003, Anthony Cooper shot Kali Mundy four times below the waist. See Cooper v. Lafler, 376 Fed. Appx. 563, 565 (6th Cir.
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Additional Resources
Am. Crim. L. Rev., Genny Ngai: Lafler v. Cooper: Attorney Mistakes, Plea Bargaining, and Remedies (Sept. 25, 2011)
Bizarro Law, LLC: High Court to Tackle Ineffective Assistance (Jan. 20, 2011)