Missouri v. Galin E. Frye, 566 U.S. 134 (2012), was a case in which the United States Supreme Court ruled that attorneys of criminal defendants have the duty to communicate plea bargains offered to the accused.

[2] Frye filed for postconviction relief, claiming that his attorney's failure to communicate the plea offers denied him of his right to effective counsel.

In oral arguments, Missouri Attorney General Chris Koster argued that Frye's guilty plea was "voluntary, intelligent, and final" under Hill v. Lockhart and Premo v. Moore.

[4] Emmett Queener, Frye's counsel, argued that "fundamental fairness and reliability of criminal process requires that an attorney provide his client information regarding matters in this case".

The Court held that "defense counsel has the duty to communicate formal offers from the prosecution to accept a plea on terms and conditions that may be favorable to the accused".