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Missouri v. Frye

United States Supreme Court
132 S.Ct. 1399 (2012)


Facts

Galin Frye (defendant) was charged with driving with a revoked license. Because he had been convicted for the same offense on three other occasions, Frye was indicted for a Class D felony that carried a minimum of four years in prison. The prosecutor sent a letter to Frye’s counsel offering a choice of two plea bargains, one being a three-year sentence but with a recommendation that Frye only serve 10 days in jail and the other reducing the charge to a misdemeanor and 90 days to serve in jail. However, the letter stated that the plea offers expired within a few weeks. Frye’s attorney never communicated the plea bargain offers to him and the offers lapsed. Eventually, Frye pled guilty to the offense without a plea bargain offer. The trial court sentenced Frye to three years in prison. Frye subsequently filed for post-conviction relief in state court alleging that his attorney’s failure to communicate the plea offers to him denied him effective assistance of counsel in violation of the Sixth Amendment. The trial court denied Frye’s motion for relief. The court of appeals reversed and held that Frye met the requirements for a showing of a Sixth Amendment violation under Strickland v. Washington, 466 U.S. 668 (1984). The U.S. Supreme Court granted certiorari to review.

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Dissent (Scalia, J.)

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