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Criminal Procedure Keyed to Allen
Lafler v. Cooper
Citation:
566 U.S. 156 (2012)Facts
Cooper was charged with assault with intent to murder, along with three other offenses. The prosecution offered to dismiss two of the charged, and to recommend a sentence of 51 to 85 months months in prison on the remaining two charges, in exchange for a guilty plea. Cooper communicated to the trial judge his willingness to accept the plea offer and admit his guilt. But he ultimately rejected the plea offer, allegedly because his defense counsel advised him that the prosecution would not be able to prove his intent to kill because the victim had been shot below the waist. At trial, Cooper was convicted on all counts and received a mandatory minimum sentence of 185 to 360 months in prison. In a postconviction motion, Cooper alleged ineffective assistance of counsel in connection with his attorney’s advice to reject the plea offer. The postconviction court rejected the claim, and the Michigan Court of Appeals affirmed. Cooper then filed a federal habeas corpus petition raising the same claim of ineffective assistance.
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