If a defense attorney advises a client to reject a favorable plea offer based on a grave miscalculation about the viability of a legal defense, has the attorney provided deficient performance?

QUESTION PRESENTED Mr. Ramet strangled his 20-year-old daughter Amy to death. He admitted he took a break in the middle of strangling her, which made a first-degree murder conviction a foregone conclusion at trial. But Mr. Ramet’s trial attorney convinced him to turn down a favorable plea deal for 15 years to life based on an unreasonable belief Mr. Ramet had “a really good shot at a manslaughter” defense. That defense unsurprisingly failed at trial; the jury convicted him of first-degree murder and sentenced him to life without the possibility of parole. Mr. Ramet pursued habeas relief under the theory he received ineffective assistance during the plea negotiations. See Lafler v. Cooper, 566 U.S. 156 (2012). The court of appeals below rejected the claim. In its view, even if the attorney “gravely miscalculated Ramet’s chances of obtaining a manslaughter conviction at trial,” Mr. Ramet still wouldn’t be entitled to relief. The question presented in this case is: If a defense attorney advises a client to reject a favorable plea offer based on a grave miscalculation about the viability of a legal defense, has the attorney provided deficient performance? i