Lafler v. Cooper

Whether a defendant is entitled to federal habeas relief based on ineffective assistance of counsel when counsel provided objectively unreasonable advice that caused the defendant to reject a plea deal, and, if so, whether the appropriate remedy is a court order that the State either offer specific performance of the rejected deal or release the defendant from custody.

Respondent Cooper was convicted of assault with intent to murder, possession of a firearm by a felon, and using a firearm during the course of a felony after he rejected a plea deal on the advice of counsel. The Michigan Court of Appeals upheld the conviction, and the Supreme Court of Michigan declined to hear the case. The United States District Court for the Eastern District of Michigan granted Cooper's petition for federal habeas corpus relief and found that Cooper's counsel had provided objectively unreasonable advice regarding the plea, and that Cooper had relied on that advice in rejecting the plea. The District Court required the state either to offer Cooper the sentencing terms of the rejected plea or to release him from custody. The 6th Circuit Court of Appeals affirmed.

On appeal the State of Michigan argues first that a decision to enter a not-guilty plea is wholly consistent with a defendant's right to a fair trial, and that the Sixth Amendment's requirements are satisfied so long as the subsequent trial is fairly conducted. The State of Michigan further argues that because there is no “substantive or procedural right” to a plea deal, and “there is no constitutional right to plea bargain,” ineffective assistance of counsel in consideration of a plea offer does not result in a constitutional violation. Finally, the State of Michigan argues that there is no rational remedy for this kind of alleged ineffective assistance of counsel, that if the State is required to offer specific performance of a plea after a fair trial Cooper will be placed in a better position than he would have been in if his counsel had rendered effective assistance, and that the order violates separation-of-power principles.