## Facts

- Michael Joe Williams, an Oklahoma prisoner, faced a first-degree murder charge.
- Before trial, the prosecutor offered a plea bargain: a 10-year sentence in exchange for a guilty plea to second-degree murder.
- Williams wanted to accept the offer, but defense counsel—believing Williams was innocent—threatened to withdraw if Williams accepted the plea.
- Williams proceeded to trial, was convicted of first-degree murder, and received life imprisonment without parole.
- On direct review, the Oklahoma Court of Criminal Appeals (OCCA) found counsel constitutionally ineffective during plea negotiations and found prejudice from the lost plea opportunity.
- Believing state law constrained its remedial options, the OCCA modified the sentence to life with the possibility of parole (the lowest punishment for first-degree murder under state law), rather than restoring the plea opportunity.
- Williams sought federal habeas relief under 28 U.S.C. § 2254, arguing the state remedy did not cure the Sixth Amendment violation; the federal district court denied relief because the modified sentence was within the state statutory range.

## Issues

1. Whether, after a state court finds ineffective assistance of counsel that caused rejection of a favorable plea offer, modifying the sentence within the statutory range for the conviction offense is a constitutionally adequate remedy.
2. Whether federal habeas courts may order relief not confined by state-law remedial limits when necessary to cure the Sixth Amendment injury from plea-stage ineffective assistance.

## Decision

- The Tenth Circuit reversed the district court’s denial of habeas relief.
- The court held the OCCA’s remedy was constitutionally inadequate because it did not address the specific injury: the loss of the favorable 10-year plea opportunity.
- The court remanded with instructions that the district court impose a remedy that comes as close as possible to curing the constitutional violation and is not limited by state law.

## Legal Principles

- Ineffective assistance of counsel in plea bargaining is evaluated under Strickland v. Washington and Hill v. Lockhart: the defendant must show deficient performance and prejudice, including that he would have accepted the plea but for counsel’s deficient conduct.
- A procedurally fair trial does not necessarily eliminate prejudice from counsel’s plea-stage ineffectiveness when the defendant lost a materially more favorable plea outcome.
- Remedies for constitutional violations must be tailored to the injury and should not unnecessarily infringe competing interests; a sentence that is merely lawful under state sentencing ranges may still fail to cure the federal constitutional harm.
- On federal habeas review, when relief is warranted, the remedial authority must provide an effective cure for the federal violation and is not constrained by state-law limits that would prevent meaningful relief.

## Conclusion

The Tenth Circuit held that when ineffective assistance causes a defendant to forgo a favorable plea bargain, the remedy must target the lost plea opportunity rather than merely adjust the post-trial sentence within the statutory range, and it directed the federal court to craft relief that most nearly restores the defendant to the position he would have occupied absent the Sixth Amendment violation.


Williams v. Jones, 571 F.3d 1086 (10th Cir. 2009)