ability of prosecutors to coerce guilty pleas has increased so dramatically.”); cf. Cynthia Alkon, The U.S., Supreme Court’s Failure to Fix Plea Bargaining: The Impact of Lafler and Frye, 41 Hastings Const. L.Q. 561, 590 (2014) (“Prosecutors, in particular, would resist plea bargaining reform if such changes were thought to undermine their power in the system, which, in part, en ables them to exercise control over their caseloads.”). The rise in plea deals led the Supreme Court in 2012 to confront the issue of whether the right to counsel in criminal cases, extends to the plea bargaining process in a pair of companion eases. See Lafler v. Cooper, — U.S.-, 132 S.Ct. 1376, 182 L.Ed.2d 398 (2012); Frye, 132 S.Ct. at 1399. It found that counsel was required. See Lafler, 132 S.Ct. at 1384 (<HOLDING>); Frye, 132 S.Ct. at 1399 (holding that, as a
recognizing that a criminal defendants right to counsel is the right to the effective assistance of counsel holding that the defendant was denied his right to the effective assistance of counsel when a codefendants plea bargain including a promise to testify against the defendant was negotiated by the law partner of the defendants counsel holding that if plea bargain has been offered defendant has right to effective assistance of counsel in considering whether to accept it holding that right to effective assistance of counsel requires that defendant be advised of immigration consequences of plea holding a criminal defendant has the right to effective assistance of counsel during a plea process