New Mexico Supreme Court

State v. Trammell

August 4, 20162016 NMSC 30

Summary

The New Mexico Supreme Court reversed the Court of Appeals and remanded for entry of an order denying the defendant’s motion to withdraw his guilty plea, holding that while counsel’s failure to advise of SORNA registration was per se deficient performance, the defendant failed to show the requisite prejudice under Strickland. The Court affirmed the retroactive application of State v. Edwards and applied a de novo standard to the prejudice analysis.