Blaine Lafler, Petitioner v. Anthony Cooper
The Court ruled that when a lawyer's ineffective assistance leads to the rejection of a plea agreement, a defendant is entitled to relief if the outcome of the plea process would have been different with competent advice.
566 U.S. 156 · No. 10-209 · 2011 term · Roberts Court
Decided Mar 21, 2012 · argued Oct 31, 2011
Civil rights · Indigents: inadequate representation by counsel
Majority opinion: Anthony Kennedy
The voteMajorityDissent
5–45 in the majority, 4 in dissent
4 dissents (5–4)
Vacated and remanded. Blaine Lafler, Petitioner won.
What this ruling means
Vacated and remanded: the Supreme Court set aside the decision of the U.S. Court of Appeals, Sixth Circuit, wiping it out without necessarily saying the result was wrong, and sent the case back for that court to decide again under the right legal standard.
Blaine Lafler, Petitioner was the petitioner, the side that asked the Supreme Court to review the case. “Won” means the Court gave that side the result it asked for.
From the Supreme Court Database. A justice who agreed with the result but not the reasoning counts in the majority.
Summary
The opening of the case’s Wikipedia article: what the case was about and what the Court held.
Lafler v. Cooper, 566 U.S. 156 (2012), was a United States Supreme Court case in which the Court clarified the Sixth Amendment standard for reversing convictions due to ineffective assistance of counsel during plea bargaining. The Court ruled that when a lawyer's ineffective assistance leads to the rejection of a plea agreement, a defendant is entitled to relief if the outcome of the plea process would have been different with competent advice. In such cases, the Court ruled that the Sixth Amendment requires the trial judge to exercise discretion to determine an appropriate remedy.
Anthony Cooper was charged by the State of Michigan with assault with intent to murder and three other offenses. After being incorrectly advised by his lawyer that the prosecution would be unable to prove intent to murder, he rejected a plea bargain. After being convicted at a fair trial, he appealed his conviction, arguing that his lawyer had provided ineffective assistance of counsel by advising him to reject the plea deal. Michigan courts denied him relief, but federal courts granted a writ of habeas corpus requiring the State to reduce Cooper's sentence to the one he would have received under the plea agreement. The State appealed to the Supreme Court, which agreed to hear the case.
Writing for the 5–4 majority, Justice Kennedy ruled that ineffective assistance of counsel during plea negotiations can constitute grounds for relief if there is a fair probability that defense counsel's ineffective assistance resulted in a harsher sentence or conviction. In those cases, Justice Kennedy wrote, trial judges should exercise discretion in choosing to vacate a conviction and accept the original plea bargain, resentence the defendant, or leave the original conviction undisturbed. Justice Scalia wrote a dissenting opinion joined by Justice Thomas and Chief Justice Roberts (in large part) which argued that the majority had invented a constitutional right to plea bargain. Justice Alito also wrote a dissenting opinion in which he largely agreed with Justice Scalia and specifically argued that the majority's remedy was unsound.
Reactions following the Supreme Court's ruling were mixed, with some commentators praising the Court's recognition of the role of plea bargaining in criminal justice and others criticizing the implications of not sufficiently protecting defendants' rights and of requiring defense counsel to plea bargain at the desire of the prosecutor.
Data notes
The text is Wikipedia’s (CC BY-SA 4.0), matched to the case by its citation, docket number or name and year, and is not checked against the opinion. The site keeps the article’s opening section, ending on its last full sentence. The one-sentence summary under the title is the Decisions list’s: Wikipedia’s own ruling sentence, or, tagged “AI-written”, one Claude wrote from this opening.
How the justices voted
Each justice who took part, placed by their Martin–Quinn ideology score for the 2011 term. Filled: the 5 in the majority. Hollow: the 4 in dissent. Colour is the party of the president who appointed them.
Majority(5)
Anthony KennedyWrote the majority opinion
Ruth GinsburgJoined the majority
Sonia SotomayorJoined the majority
Elena KaganJoined the majority
Stephen BreyerJoined the majority
Dissent(4)
Samuel AlitoWrote a dissent
Antonin ScaliaWrote a dissent
John RobertsJoined a dissent
Clarence ThomasJoined a dissent
Data notes
Each justice’s vote and what they wrote are from the justice-centered file of the Supreme Court Database. “Wrote a concurrence” means the justice sided with the majority and wrote separately; a justice who dissented in part is counted on the side they took overall. A justice who wrote nothing is listed as joining their side.
Positions are each justice’s Martin–Quinn score for the case’s term, the same scores as the Ideology page: negative is more liberal, positive more conservative. A score sums up a justice’s votes across the whole term, so it says where they usually sit, not why they voted as they did here. The median line is the Court’s median justice that term.
The parties
Who brought the case to the Court, who answered it, and how it got there.
- Petitioner
- Blaine Lafler, PetitionerPerson convicted of crime
- Respondent
- Anthony CooperState (Michigan)
- Reached the Court by
- Certiorari (the Court chose to hear it)
Data notes
The names are the two sides of the case’s title. The description under each is the Supreme Court Database’s category for that party, in its own wording. The petitioner is the side that asked the Supreme Court to review the decision below. “Why it was taken” appears only when the majority opinion says lower courts disagreed or were unsure about the question; reasons that would fit any case (“to resolve the question presented”, “an important question”) are left out.
The law at issue
The law the Court was asked to apply, and the kind of power it used to decide.
- Provision
- Sixth Amendment (right to counsel)
- Kind of law
- Constitutional Amendment
- Decided by
- Judicial review (state level); Federal common law
Data notes
The Supreme Court Database codes the main constitutional provision, statute or court rule each case turned on, and the basis of the decision: judicial review of a federal or state law, interpreting a statute, supervising the lower courts, and so on. A case can rest on more than one. “Overruled” counts only where the majority opinion says so.
Timeline
What happened at the Court and how the case got there, newest first.
- Mar 21, 2012DecidedDecided · Decided 5–4: vacated and remanded. Blaine Lafler, Petitioner won.
- Oct 31, 2011ArguedArgued · Oral argument before the Court.
- Not datedTaken upTaken up · The Supreme Court agreed to hear the case (certiorari).
- Not datedCourt belowCourt below · Decided by the U.S. Court of Appeals, Sixth Circuit: affirmed.
- Not datedBeganBegan · The case began in the Michigan Eastern U.S. District Court.
Data notes
From the Supreme Court Database: the court the case began in, the court whose decision the Supreme Court reviewed and what that court did, how the case came to the Court, and the dates of argument and decision. The database does not date the steps in the lower courts. Court names are the database’s.
Other decisions on the same issue
14 other argued cases since 1946 on indigents: inadequate representation by counsel, newest first.
- Weaver v. Massachusetts137 S. Ct. 1899Jun 22, 2017 · 137 S. Ct. 1899Civil rights7–27–2 band
- Carlos Trevino, Petitioner v. Rick Thaler, Director, Texas Department of Criminal Justice, Correctional Institutions Division569 U.S. 413May 28, 2013 · 569 U.S. 413Civil rights5–45–4 band
- Missouri, Petitioner v. Galin E. Frye566 U.S. 134Mar 21, 2012 · 566 U.S. 134Civil rights5–45–4 band
- Luis Mariano Martinez, Petitioner v. Charles L. Ryan, Director, Arizona Department of Corrections566 U.S. 1Mar 20, 2012 · 566 U.S. 1Civil rights7–27–2 band
- James Walker, Warden, et al., Petitioners v. Charles W. Martin562 U.S. 307Feb 23, 2011 · 562 U.S. 307Civil rights9–0Unanimous band
- Jeff Premo, Superintendent, Oregon State Penitentiary, Petitioner v. Randy Joseph Moore562 U.S. 115Jan 19, 2011 · 562 U.S. 115Civil rights8–0Unanimous band
- Albert Holland v. Florida560 U.S. 631Jun 14, 2010 · 560 U.S. 631Civil rights7–27–2 band
- Michael A. Knowles, Warden v. Alexandre Mirzayance556 U.S. 111Mar 24, 2009 · 556 U.S. 111Civil rights9–0Unanimous band
- Penson, Steven A. v. Ohio488 U.S. 75Nov 29, 1988 · 488 U.S. 75Civil rights8–18–1 band
- McCoy v. Court of Appeals of Wisconsin, District 1486 U.S. 429Jun 6, 1988 · 486 U.S. 429Civil rights5–36–3 band
- Strickland, Superintendent, Florida State Prison, et al. v. WashingtonLandmark · Other rights regarding counsel466 U.S. 668May 14, 1984 · 466 U.S. 668Civil rightsLandmark · Other rights regarding counsel8–18–1 band
- Wood et al. v. Georgia450 U.S. 261Mar 4, 1981 · 450 U.S. 261Civil rights6–36–3 band
- Holloway et al. v. Arkansas435 U.S. 475Apr 3, 1978 · 435 U.S. 475Civil rights6–36–3 band
- Johnson v. Avery, Commissioner of Correction, et al.393 U.S. 483Feb 24, 1969 · 393 U.S. 483Civil rights7–27–2 band
Data notes
Every other orally argued case with a clear vote, from the 1946 term on, that the Supreme Court Database files under the same issue as this one. The database gives each case one issue from a list of about 270 (abortion, search and seizure of vehicles, the death penalty, and so on), whatever law it turned on.
Official record
Read the full opinion on Justia, the argument audio on Oyez and Wikipedia. Case data from the Supreme Court Database, Version 2026 Release 01, through the 2025 term.