On March 21, 2012, the Supreme Court decided two cases in which it found, by a 5-4 vote, that the standards of ineffective assistance of counsel (set forth earlier in Strickland v. Washington, 466 U.S. 668 (1984)) apply to the plea bargaining stage of a case. In so holding, the Court found that counsel was ineffective when in one case (Lafler v. Cooper), the defendant chose to reject a plea offer based on incorrect advice given by counsel about a legal rule in the case, went instead to trial and lost, and then received a significantly greater sentence; and in another case (Missouri v. Frye), the defendant lost the opportunity to plead to a misdemeanor because counsel never shared with the defendant the plea offer before it lapsed, thereby leading the defendant to plead to a felony charge with a higher sentence. In his dissent, Justice Scalie bemoaned that the Court’s opinions would create a “whole new field of constitutionalized criminal procedure: plea-bargaining law.” To read the full opinion please see our link under Law - Case Law - US Supreme Court.