Alcorn v. State
Annotate this CaseThe State charged Defendant with two drug-related offenses. Defendant rejected a twelve-year plea offer after being incorrectly advised that his maximum sentence was thirty years when, in fact, Defendant faced a maximum sentence of life in prison. After trial, Defendant was found guilty of simple sale of cocaine and possession of cocaine and was sentenced to thirty years imprisonment. The court of appeal affirmed, concluding that Defendant could not show prejudice because he ultimately received the same sentence as what he was incorrectly advised. Subsequent to the court of appeal's decision, the U.S. Supreme Court issued two decisions - Missouri v. Frye and Lafler v. Cooper - concerning ineffective assistance of counsel claims in which the defendant rejected a pea offer based on misadvice. In light of these two cases, the Florida Supreme Court receded from its decisions in Cottle v. State and Morgan v. State with respect to what a defendant must show in order to demonstrate prejudice. After clarifying what a defendant must show to demonstrate prejudice, the Court quashed the court of appeal's decision because it incorrectly analyzed the prejudice prong. Remanded.
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