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4th DCANovember 12, 2025Affirmed📋 Rule Change

Key v. State

Case No. 4D2024-2536

On remand after a prior ruling that Key received ineffective assistance of counsel causing him to reject a favorable plea offer, the trial court reimposed Key's original 30-year sentence rather than accept the State's 15-year reoffer. The Fourth District affirmed, holding that under Lafler v. Cooper the trial court has discretion to either accept the reoffered plea or leave the original sentence undisturbed.

Key facts

  • Key was convicted and sentenced to 30 years after his trial attorney provided ineffective assistance of counsel by failing to communicate a favorable plea offer.
  • On remand following a prior appellate ruling that Key received ineffective assistance, the trial court rejected the State's reoffer of a 15-year plea deal and reimposed the original 30-year sentence.
  • +1 more key fact with a free trial

Why it matters

This opinion clarifies, at the district level, that the older Lester v. State remedy framework for 'lost plea' ineffective assistance claims is superseded by the U.S. Supreme Court's decision in Lafler v. Cooper… — full analysis with a trial

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