Missouri v. Frye

Missouri v. Frye
Case Issue: Can a criminal defendant who was convicted after a jury trial later argue that his lawyer was inadequate because he failed to tell him that prosecutors had offered a deal to plead guilty in exchange for a lighter sentence? And, if so, what should courts do to correct the lawyer's error?

What happened exactly?
A defense attorney failed to inform his client, Galin Edward Frye, who had been charged with repeatedly driving while his license was revoked, of a plea offer by the prosecution. After the offer by the prosecutors expired, Frye was arrested for the fifth time then later entered a guilty plea without having the option of the plea offer and was sentenced to three years in prison.

The lawyer didn’t present the offer to the criminal defendant (Frye) therefore has violated the criminal defendant’s constitutional rights. The sixth amendment gives the criminal defendant the right to plead guilty if you choose too. In other words, you have a right to a fair trial. The amendment relates to the case because the counsel’s failure to communicate the plea offer prior to its expiration resulted in Frye not being able to plead guilty. During this seating, Attorney General Koster will advocate the law-enforcement position that Mr. Frye’s conviction should stand, and he should not be allowed to withdraw his guilty plea.

Missouri argues that Frye’s request gives attorneys the opportunity to strategically use plea offers as insurance policies against trial results that aren’t unpredictable. Missouri assures that, an attorney can allow a plea offer to expire without communicating it to the defendant, which means the lawyer wants the defendant has to stand trial hoping for a lighter sentence.  

In this case, the Supreme Court has to decided whether the Sixth Amendment’s right to a fair trail and having effective assistance of counsel protects the criminal defendant whose attorney has not communicated the available plea bargain options,

Respondent Frye argues that his counsel’s failure to inform him of his plea offer was unreasonable and it prejudiced him. However, the State of Missouri maintains that Frye fails the prejudice requirements because prejudice requires a showing that, in the absence of attorney error, Frye would have pled not guilty and gone to trial.

Connection/Relation to other cases:
Missouri v. Frye case is connected to Lafler v. Cooper’s case, the only difference between the two cases is that the Lafler v. Cooper’s case criminal defendant decided to ignore the lawyer’s offer by pleading guilty, got a harsher sentence, and now wants to have privilege of that offer, which was admitting to the crime for a lighter sentence. Missouri v. Frye case criminal defendant was not notified of the deal the prosecutors offered, received a harsher sentence and now wants an opportunity to gain the right his lawyer failed to notify him of.


William Lloyd Hill pleaded guilty in the Arkansas trial court to charges of first-degree murder and theft of property. More than two years later he found out that his court-appointed attorney had failed to advise him that, as a second offender, he was required to serve one-half of his sentence before becoming eligible for parole.

My Opinion

It’s hard to say what exactly side I am on. I believe it was unfair and unjust to Frye because this situation validated his constitutional rights. He had a right to a fair trial, therefore I believe something should be done in his favor. I’m confused by Missouri’s side of defense because they are saying there needs to be proof that Frye would have pled not guilty if his lawyer had not made an error, which is assuming.  I don’t believe you can base anything of a assumption, but most likely it isn’t an assumption minding that Frye has been arresting for this crime numerous of times.  Also, the government is not responsible for any errors that were made by an lawyer.

No decision was made as of November 2, 2011. Many of the arguments are resorting back to the Hill v. Lockhart case.