(CN) - The Supreme Court on Wednesday vacated the special consideration shown to two criminal defendants who received harsh sentences after allegedly poor legal advice caused them to turn down more favorable plea deals.
Justice Anthony Kennedy authored the majority opinions in each case.
The first case concerns Galin Frye, whom Michigan authorities charged with driving on a revoked license in 2007. The maximum sentence for the class D felony with which he was charged is four years in prison.
Though the prosecutor sent Frye's lawyer two plea deals, the attorney never shared the offers with Frye and the deals expired. With a week to go before trial, on Dec. 30, 2007, Frye was arrested again for the same offense. After pleading guilty to the original charges, the trial judge sentenced him to three years in prison.
Under the original offer, however, Frye could have pleaded guilty to a misdemeanor and served 90 days.
Frye testified in postconviction hearing that he would have pleaded to the misdemeanor if he knew about the offer, but the court denied his claim of ineffective counsel. The Missouri Court of Appeals was more sympathetic, however, and withdrew Frye's guilty plea. It ordered the trial court to let Frye go to trial or plead guilty to any offense at the prosecutor's discretion.
Blaine Lafler also lost out on a more favorable plea deal in Michigan, but he rejected it on his attorney's advice. Lafler was facing a mandatory-minimum sentence of 15 to 30 years in prison for weapon and drug charges, as well as intent to murder.
The prosecutors twice offered to dismiss two charges and recommend a maximum sentence of seven years.
Though Lafler admitted guilt in communication with the court, and indicated that he wanted to plead down, his attorney allegedly convinced him to turn down the offer. After his conviction, the court sentenced Lafler to the mandatory minimum.
Lafler exhausted his postconviction relief options in state court but fared better in U.S. District Court. A federal judge ordered specific performance of the original deal, for a minimum sentence of 51 to 85 months. The 6th Circuit affirmed.
The Supreme Court voted 5-4 Tuesday to vacate both Frye and Lafler's appellate successes.
Though it was deficient for Frye's attorney to shield the formal plea offer from his client, Frye has not shown prejudice from the breach of duty, according to the court.
"A defendant in Frye's position must show not only a reasonable probability that he would have accepted the lapsed plea but also a reasonable probability that the prosecution would have adhered to the agreement and that it would have been accepted by the trial court," Kennedy wrote. "Frye can show he would have accepted the offer, but there is strong reason to doubt the prosecution and the trial court would have permitted the plea bargain to become final."
On remand, the Missouri Court of Appeals must consider if the prosecution would have adhered to the plea offer, and if the trial court would have accepted it.