Latest Case: United States v. Knight (Criminal Law)

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United States v. Knight

Docket: 19-3016

Opinion Date: December 8, 2020

Judge: Judith Ann Wilson Rogers

Areas of Law: Criminal Law

Defendants Knight and Thorpe were convicted on a ten-count indictment for charges related to armed robbery and kidnapping. Knight was sentenced to more than 22 years' imprisonment and Thorpe was sentenced to 25 years' imprisonment. Defendants were originally given a plea offer with a lesser sentence of two to six years' imprisonment, but Knight's counsel erroneously advised him that the offer came with ten years' imprisonment. Because Knight rejected the offer, the plea was no longer available to both defendants. On appeal, defendants argued that they had been denied effective assistance of counsel in violation of the Sixth Amendment. The DC Circuit concluded that defendants' claims were colorable and remanded the case. The district court then denied relief. The DC Circuit now reverses in part, holding that Knight satisfied his burden under both prongs of the standard for an ineffective assistance of counsel claim. The court explained that the performance by Knight's counsel did not meet minimal professional standards, and the district court's determination that Knight suffered no prejudice rested on subsidiary factual findings that ignored the direct effect of his counsel's deficient performance on Knight's ability to intelligently assess his options and therefore were clearly erroneous. Viewed properly, the court explained that the contemporaneous evidence and Knight's testimony at the evidentiary hearing sufficed to establish a reasonable probability that Knight would have accepted the plea offer but for his counsel's ineffective assistance. However, the court agreed that Thorpe's counsel was not ineffective and there was no violation of his Sixth Amendment rights. Accordingly, the court affirmed in part. The court remanded to the district court for further proceedings.