Lawyer advice on plea deals
Burt v. Vonlee Nicole Titlow
In brief
The Supreme Court overturned the Sixth Circuit because it did not give enough weight to Michigan's decision and assumed Titlow's lawyer was ineffective despite a silent record.
- Where it stands
- Decided
Decided 9-0 · November 5, 2013 · Opinion by Justice Sotomayor
- What it’s about
- Vonlee Titlow said her new lawyer’s advice led her to withdraw a plea deal, and the Sixth Circuit ruled that she had received ineffective legal help.
- Who it affects
- The Sixth Circuit's ruling that Titlow received ineffective legal help was overturned.
Summary: written with AI from the case record.
What it's about
The Supreme Court overturned that ruling because the appeals court failed to give the Michigan court’s factual finding the required deference and treated the lawyer as ineffective despite a silent record.
Justice Ginsburg's separate opinion said the plea deal depended on Titlow testifying at her aunt's trial. She said the deal failed when Titlow withdrew that commitment.
The case concerned how federal appeals courts must review state-court decisions about claims of poor legal representation.
Question presented
1. Did the Sixth Circuit give appropriate deference to the Michigan trial court under the AEDPA? 2. Can a defendant establish prejudice in an ineffective assistance claim by presenting subjective testimony that he would have accepted the plea offer absent the attorney's deficient advice? 3. Does the Court's decision in Lafler v. Cooper require a state trial court to resentence a defendant when he claims that ineffective assistance of counsel led him to reject a plea offer?
What the Court decided
Holding
The Sixth Circuit failed to apply the “doubly deferential” stand - ard of review recognized by the Court’s case law when it refused to credit the state court’s reasonable factual finding and assumed that counsel was ineffective where the record was silent. 680 F. 3d 577, reversed.
- Result
- Reversed
The Court's reasoning
The Court said the Sixth Circuit had to give strong weight to the Michigan court's decision. It faulted the appeals court for rejecting a reasonable factual finding and assuming the lawyer was ineffective even though the record was silent.
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Majority · 8joined the Court's opinion
- Concurring · 1agreed with the result, wrote separately
- Ginsburgwrote separately
What's next
The Supreme Court overturned the Sixth Circuit ruling. Its stated action does not say the case was sent back to a lower court.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
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Opinion added: Burt
More questions
- What did Justice Sotomayor emphasize?
- She said Titlow did not offer enough evidence about what her lawyer did in the days before she withdrew her plea.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.