Missouri v. Frye

Facing a felony charge carrying up to four years for driving with a revoked license (his fourth such offense), Galin Frye (defendant) never learned that the prosecutor had offered his attorney two favorable plea deals — a three-year sentence recommending only 10 days served, or a reduced misdemeanor charge with 90 days served — because his attorney never communicated either offer before both expired. Frye instead later pled guilty without any plea bargain and was sentenced to three years; he sought post-conviction relief claiming his attorney's failure to communicate the offers violated his Sixth Amendment right to effective counsel under Strickland v. Washington. The trial court denied relief, but the court of appeals reversed, and the U.S. Supreme Court granted certiorari.