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Criminal Procedure keyed to Kamisar
Missouri v. Frye
Citation:566 U.S. 134, 132 S.Ct. 1399, 182 L.Ed.2d 379 (2012)
Frye was charged with driving with a revoked license. The prosecutor sent a letter to Frye’s attorney offering to reduce the charge to a misdemeanor and recommend a 90-day sentence. Frye’s attorney did not inform him of the offers. Once the offers expired, Frye pled guilty without an underlying agreement and was sentenced to three years in prison. At a post-conviction hearing, Frye stated he would have pled guilty to a misdemeanor if he had known about the offer.
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