The US Supreme Court has declined to consider the issue of when defense lawyers are obligated to begin negotiating a plea deal for their clients. The court’s decision came in a case brought by Quartavious Davis, who argued that his lawyer failed to properly advise him on whether to plead guilty or go to trial for seven armed robberies he committed in 2010 when he was 18 and 19 years old. Davis pleaded not guilty and went to trial, where he was convicted and sentenced to 159 years in prison for crimes he committed with other individuals. His co-defendants, who pleaded guilty, received lighter sentences.
Two individuals who participated in six robberies with Davis each received 32-year prison sentences, which were reduced to slightly over 19 years. Davis argued that his attorney knew before his trial that the government planned to introduce evidence linking his cell phone to six of the seven robberies and that some or all of his co-defendants could testify against him. The district court and the US Court of Appeals for the Eleventh Circuit denied his request to vacate, correct, or set aside his sentence. The appeals court said that Davis had not demonstrated that his attorney was ineffective or that he was prejudiced by his attorney’s failure to negotiate a plea deal.
According to the appeals court, Davis never alleged that the government offered him a plea deal nor that he would have accepted one. However, Davis argues that a defendant can establish prejudice without a government offer. The federal government countered that the Supreme Court has never recognized such a low standard for claims of ineffective assistance of counsel and should not do so in this case.
Justice Ketanji Brown Jackson said in a dissenting opinion that she would have heard the case, which presented “a clear opportunity for the court to resolve a circuit split regarding whether having an actual plea offer is an indispensable prerequisite to making the necessary showing of prejudice.” According to Jackson, given the circumstances presented in this case, it was highly probable that Davis would have succeeded in his claim that his defense counsel’s inadequate performance harmed him.
The court’s decision not to hear Davis’s case means that the current standards for determining when defense lawyers must begin plea negotiations remain unchanged. As a result, the issue will continue to be decided on a case-by-case basis, leaving defendants vulnerable to the possibility of being unfairly convicted or sentenced due to inadequate representation by their attorneys.
Overall, the case highlights the importance of effective representation for defendants in criminal cases and the need for clear and consistent standards for determining when plea negotiations should begin. Without such standards, the risk of unfair and unjust outcomes in criminal cases remains high, particularly for defendants who lack the financial resources to hire top-tier legal representation.
REFERENCES:
US Supreme Court Refuses to Weigh Ineffective Counsel Claims (1)