Lafler v. Cooper, 132 S.Ct. 1376 (Mar. 21, 2012) (defendant received ineffective assistance of counsel during plea bargaining, in rejecting an offer of a 51-to-85-month sentence, because counsel misadvised him that the prosecution would be unable to establish intent to murder, prejudice can be shown by establishing a reasonable probability the defendant and the trial court would have accepted the more favorable guilty plea absent counsels error).

NOTE: The majority cites Padilla's floodgates discussion in defending the point that "Courts have recognized claims of this sort for over 30 years" without creating undo chaos. By "this sort," they mean Strickland claims about rejected pleas, which have a little bit more of a pedigree than non-advisal Padilla claims. This is another case with an application of Strickland that the dissent claims is novel. This language is strong confirmation that the Court understands Padilla's floodgates discussion as assuming its radioactivity as a mere application of Strickland and not a new rule. Thanks to Dan Kesselbrenner and Isaac Wheeler.