''Garza v. Idaho'', 586 U.S. ___, 139 S. Ct. 738 (2019), was a case in which the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

held that the presumption of prejudice for Sixth Amendment purposes applies regardless of whether a defendant has waived the right to appeal.

Background

In 2015, petitioner Gilberto Garza, Jr. signed two plea agreements which required him to waive his right to appeal. After sentencing, Garza informed his trial counsel of his wish to appeal. Due to the appeal waivers signed by Garza, counsel declined to file a notice of appeal. After the time period to file an appeal lapsed, Garza filed a petition for state post-conviction relief on the basis of

ineffective assistance of counsel In United States law, ineffective assistance of counsel (IAC) is a claim raised by a convicted criminal defendant asserting that the defendant's legal counsel performed so ineffectively that it deprived the defendant of the constitutional right gua ...

. The trial court denied relief and the

Idaho Court of Appeals The Idaho Court of Appeals is the intermediate-level appellate court for the state of Idaho. The court was created by statute by the Idaho Legislature and began operations in 1982. Jurisdiction The Court of Appeals hears cases assigned to it by t ...

affirmed. The

Idaho Supreme Court The Idaho Supreme Court is the state supreme court of Idaho and is composed of the chief justice and four associate justices. The decisions of the Idaho Supreme Court are binding on all other Idaho state courts. The only court that may reverse ...

affirmed, concluding that the presumption of prejudice as recognized in ''Roe v. Flores-Ortega'' does not apply when the defendant has agreed to waive the right to appeal.

Opinion

Amir Ali presented oral argument for Garza before the Supreme Court, with Ken Jorgensen and Alon Kedem representing the State of Idaho and United States, respectively. The Court announced its judgment in favor of the petitioner on February 27, 2019, with the court reversing and remanding by a vote of 6–3..

Opinion of the Court

The majority opinion, written by Sotomayor and joined by Roberts, Ginsburg, Breyer, Kagan, and Kavanaugh, held that Garza's trial counsel rendered ineffective assistance. In ''

Strickland v. Washington ''Strickland v. Washington'', 466 U.S. 668 (1984), was a landmark Supreme Court case that established the standard for determining when a criminal defendant's Sixth Amendment right to counsel is violated by that counsel's inadequate performance ...

'', the Supreme Court held that a defendant claiming ineffective assistance of counsel must prove counsel's representation fell below an objective standard of reasonableness and such deficiency was prejudicial to the defense.

Dissent

Justice Thomas, joined by Gorsuch and joined in part by Alito, filed a dissenting opinion which held that the defense acted reasonably by refusing to file an appeal. The dissent argued that the majority's opinion creates a "defendant-always-wins" rule that has no basis in previous case law or the Sixth Amendment. Part III of Thomas' dissent, joined by Gorsuch but not Alito, suggests the landmark ''

Gideon v. Wainwright ''Gideon v. Wainwright'', 372 U.S. 335 (1963), was a landmark U.S. Supreme Court decision in which the Court ruled that the Sixth Amendment of the U.S. Constitution requires U.S. states to provide attorneys to criminal defendants who are unable ...

'' (1963, guaranteeing poor defendants a right to a lawyer in state criminal cases) was wrongly decided and should be overruled.

References

External links