State v. Taccetta, 200 N.J. 183

Summary

The Supreme Court of New Jersey held that Martin Taccetta could not establish prejudice from alleged ineffective assistance of counsel because the proposed guilty plea required him to provide a false factual basis for aggravated manslaughter. The court ruled that New Jersey courts may not accept or authorize a guilty plea based on known perjury, reversed the Appellate Division, vacated post-conviction relief, and reinstated Taccetta's convictions and sentence.

Holdings

1. A defendant cannot establish prejudice under the ineffective-assistance standard when the proposed plea required him to give a knowingly false factual basis for an offense he maintains he did not commit, because a New Jersey court may not accept or sanction such a plea.

Questions Presented

1. Whether counsel's allegedly deficient advice about sentencing consequences caused constitutionally cognizable prejudice under the Strickland/Fritz ineffective-assistance standard.
2. Whether a defendant who claims innocence and would have committed perjury to establish a factual basis could demonstrate that he would have accepted a guilty-plea offer.
3. Whether the PCR court could vacate a jury verdict and grant a new trial based on a plea that the trial court could not lawfully accept.

Disposition

reversed_and_remanded