New Mexico Supreme Court

State of New Mexico, Plaintiff-Petitioner v. Lucas Trammell, Defendant-Respondent

August 4, 201610 N.M. 353

Summary

The New Mexico Supreme Court held that although Lucas Trammell’s counsel failed to advise him of the SORNA registration requirement—constituting deficient performance under Strickland—the defendant did not demonstrate the requisite prejudice, so his motion to withdraw the guilty plea was denied. The Court also affirmed that the Edwards decision applies retroactively because it did not create a new rule.