Burt v. Titlow
State appeal
State appeal
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Removing Toca as counsel Titlow appealed to the Michigan Court of Appeals. She argued that Toca had advised her to withdraw her plea without doing any research on her case therefore providing her with [ineffective counsel](/wiki/Ineffective_counsel "Ineffective counsel"). The Appeals Court rejected her argument, stating that her withdrawal of the plea bargain started with her conversation with the sheriff's deputy, not Toca. The Court stated "\[w]hen a defendant proclaims…innocence…, it is not objectively unreasonable to recommend that the defendant refrain from pleading guilty\-no matter how 'good' the deal may appear".

Titlow filed a motion under The [Antiterrorism and Effective Death Penalty Act](/wiki/Antiterrorism_and_Effective_Death_Penalty_Act "Antiterrorism and Effective Death Penalty Act"), requesting a review by federal court.


Can ineffective counsel be used as an argument in court?