New Mexico v. Trammell
Annotate this CaseIn 2004, defendant Lucas Trammell pled guilty in part, to false imprisonment of a minor victim. At the time, a conviction of false imprisonment of a minor victim required that defendant register as a sex offender under the New Mexico Sex Offender Registration and Notification Act (SORNA). Defendant’s attorney failed to realize that defendant’s plea included a sex offense requiring SORNA registration. Defendant moved to withdraw his plea six years later, after he was arrested and found to have violated the terms of his probation. After review, the New Mexico Supreme Court, concluded that although counsel’s failure to advise Defendant of the SORNA registration requirement in his plea agreement was per se deficient performance under the first prong of the "Strickland" test for ineffective assistance of counsel, Defendant failed to show that under the second prong of Strickland, he had been prejudiced by that deficient performance. The Court of Appeals was reversed for holding otherwise, and remanded this case back to the district court for entry of an order denying defendant's motion to withdraw his plea agreement.
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