State v. Alfredson
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After a jury trial, Appellant was convicted of first degree sexual assault and second degree false imprisonment. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief. The district court dismissed all but one of Appellant’s claims without an evidentiary hearing. After an evidentiary hearing, the trial court denied Appellant’s remaining claim regarding trial counsel’s failure to disclose an alleged plea offer. The Supreme Court affirmed, holding (1) as a general rule, defense counsel has the duty to communicate to the defendant all formal offers from the prosecution to accept a plea on terms and conditions that may be favorable to the defendant; and (2) the district court did not clearly err in finding that the State made a formal offer, and therefore, trial counsel could not have been deficient in failing to disclose it to Appellant.
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