Missouri v. Frye

Missouri v. Galin E. Frye, 566 U.S. 134 (2012), was a case in which the United States Supreme Court ruled that attorneys of criminal defendants have the duty to communicate plea bargains offered to the accused.

Background
In August 2007, Galin Frye was arrested and charged with driving without a license for the third time, making it a felony in Missouri. The prosecutor in the case sent Frye's attorney two plea offers; one to recommend a three-year sentence with Frye serving only ten days in jail if he pleaded guilty to the felony, and the second to reduce the felony to a misdemeanor, and Frye to serve 90 days in jail. Despite these offers being made, Frye's attorney never notified him about them and they expired before being acted upon. Frye was arrested again for driving with a suspended license shortly before his preliminary hearing, after the offers had expired. He pleaded guilty to the new charge, and was sentenced to three years in prison.

Frye filed for postconviction relief, claiming that his attorney's failure to communicate the plea offers denied him of his right to effective counsel. At a preliminary hearing, he testified that had he known about the plea bargain offers, he would have pleaded guilty to the misdemeanor charge. His appeal was denied by a state court, but the decision was reversed by the Missouri Court of Appeals.

Arguments
The reversal was then appealed by the State of Missouri to the United States Supreme Court. In oral arguments, Missouri Attorney General Chris Koster argued that Frye's guilty plea was "voluntary, intelligent, and final" under Hill v. Lockhart and Premo v. Moore. He further argued that plea negotiations "are not a critical stage because ... the fate of the accused is not set", and as such the defendant is not necessarily entitled to counsel under the Sixth Amendment in this stage. Emmett Queener, Frye's counsel, argued that "fundamental fairness and reliability of criminal process requires that an attorney provide his client information regarding matters in this case". He said that Frye's plea was "unknowing and involuntary" because he was not made aware of all options that were available, including the plea bargain that was offered.

Ruling
The majority opinion, authored by Associate Justice Anthony Kennedy, ruled in favor of Frye. In the opinion announcement, Kennedy said that, while there is no right to a plea bargain, because "nearly 95% of convictions result from a plea bargain ... this Court is unwilling to say that within that system [of plea bargaining], counsel's performance does not matter". He noted that even if ineffective counsel is shown in this case, Frye would still need to show prejudice as set out in Strickland v. Washington to obtain relief. The Court held that "defense counsel has the duty to communicate formal offers from the prosecution to accept a plea on terms and conditions that may be favorable to the accused". The ruling of the Missouri Court of Appeals was vacated and the case was remanded.