Premo v. Moore
Headline: Ruling limits federal habeas relief for defendants who accept plea deals when lawyers decline suppression motions, reversing a federal appeals court and upholding state-court findings that counsel’s strategic choice was reasonable.
Holding: The Court reversed the Ninth Circuit and held that the state court reasonably found the defendant’s lawyer acted competently by not moving to suppress a police confession before a plea, so federal habeas relief is unwarranted.
- Makes it harder to overturn plea deals based on counsel’s pre-plea choices.
- Gives state courts and lawyers more deference in plea-stage decisions.
- Limits use of involuntary-confession cases to prove prejudice in plea bargains.
Summary
Background
A man convicted in Oregon, Randy Moore, attacked and killed a victim and confessed to police. He also admitted the crime to his brother and an accomplice’s girlfriend. On counsel's advice he pleaded no contest to felony murder and received the statutory minimum 300-month sentence. Moore later sued, saying his lawyer was ineffective for not moving to suppress the police confession before advising the plea. An Oregon court denied relief, the federal district court denied habeas, but the Ninth Circuit granted federal habeas relief and the Supreme Court agreed to review.
Reasoning
The Court asked whether the state court unreasonably applied the rule for lawyer incompetence (Strickland) when it found counsel reasonable. The Supreme Court held the state court’s conclusion was not unreasonable. It emphasized deference to counsel’s strategic choices, noting counsel reasonably thought a suppression motion would be futile because two other witnesses could testify to a confession and because of the risk of a capital prosecution. The Court rejected the Ninth Circuit’s reliance on a case about involuntary confessions (Fulminante) as not controlling for plea-stage lawyer performance and stressed that AEDPA requires doubly deferential review of state-court rulings.
Real world impact
The decision makes it harder for people to win federal habeas relief based on lawyers’ choices during plea negotiations when state courts reasonably found counsel acted competently. It protects the stability of plea bargains by giving weight to strategic choices made when cases are uncertain. Federal courts must show deference before overturning state findings about counsel.
Dissents or concurrances
Justice Ginsburg, writing separately, agreed with the outcome and noted Moore never said he would have rejected the plea and insisted on a trial, supporting denial of relief.
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