Whether counsel for the accused has a constitutional duty under the Sixth Amendment to document and present the client plea offers (contracts) in written form; or stated differently, is it the State's prerogative to promulgate rules that would require plea offers to be in writing to ensure against misunderstandings?

QUESTION PRESENTED!: Whether counsel for the accusedhas a constitutional duty under the Sixth Amendment to documentand present the client plea offers (contracts)in written form; or stated differently, is ; it the State’s prerogative to promulgate rules that would require plea offers to be in writing to ensure against misunderstandings? this case presents a constitutional issue that was left open inMissouri v. Frye, 566 US 134, 132 S. Ct 1399 (2012) and Lafler v. Cooper, 566 US 156, 132 S Ct 1376 (2012). Mr. Reilly’s question requires a higher level of scrutiny for the plea bargaining process; thus, applying contract law to plea offers. ii