Garza v. Idaho
139 S. Ct. 738
| SCOTUS | 2019Background
- Gilberto Garza signed two plea agreements in Idaho that included clauses waiving his right to appeal; the trial court accepted the pleas and imposed the agreed 10‑year sentences.
- After sentencing Garza repeatedly told trial counsel he wanted to appeal; counsel declined to file a notice of appeal, citing the appeal waivers.
- The statutory deadline to file a notice of appeal passed with no appeal filed; Garza then brought state postconviction relief alleging ineffective assistance for failure to file the notice.
- Idaho courts denied relief, holding Garza could not show prejudice because his plea agreements contained appeal waivers; the Idaho Supreme Court concluded Flores‑Ortega’s presumption of prejudice did not apply.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on whether Flores‑Ortega’s presumption of prejudice applies when a defendant signed an appeal waiver.
- The Supreme Court (majority) reversed Idaho, holding that Flores‑Ortega’s presumption of prejudice applies even when the defendant signed an appeal waiver, because some appellate rights remain and filing a notice is ministerial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel’s failure to file a requested notice of appeal is deficient when defendant signed an appeal waiver | Garza: counsel was deficient for disregarding repeated, clear requests to file a notice of appeal | Idaho: counsel reasonably declined because Garza waived appellate rights and filing could breach the plea bargain | Court: counsel’s failure was deficient—filing is ministerial and the decision to appeal belongs to the defendant |
| Whether Flores‑Ortega’s presumption of prejudice applies when defendant signed an appeal waiver | Garza: presumption applies—some appeal rights remain and he was deprived of the entire proceeding | Idaho/Government: no presumption—waiver means no right to an appeal, so no prejudice from counsel’s omission | Court: presumption applies regardless of an appeal waiver; prejudice is presumed when counsel’s deficiency forfeits an appeal the defendant would have taken |
| Whether a defendant must show the appeal would have contained nonwaived, nonfrivolous issues to obtain relief | Garza: no need to show merits; Flores‑Ortega displaces a merits showing | Idaho/Government: require case‑by‑case proof that nonwaived meritorious claims would have been presented | Court: rejected requiring merits showing or case‑by‑case proof; precedent forbids conditioning relief on proof of appeal merit |
| Proper remedy when counsel fails to file requested appeal despite waiver | Garza: restore opportunity to appeal (preserve status quo) | Idaho/Government: limit or deny relief because waiver negates right; require additional proof | Court: restore appellate opportunity; treat defendant as any other appellant and allow direct review with counsel’s briefing |
Key Cases Cited
- Roe v. Flores‑Ortega, 528 U.S. 470 (2000) (presumption of prejudice when counsel’s deficient performance forfeits a requested appeal)
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑part ineffective assistance standard: deficiency and prejudice)
- Jones v. Barnes, 463 U.S. 745 (1983) (defendant has ultimate authority to decide whether to appeal; counsel chooses arguments)
- Penson v. Ohio, 488 U.S. 75 (1988) (denial of counsel on appeal can justify relief)
- Anders v. California, 386 U.S. 738 (1967) (procedure for appointed counsel seeking to withdraw when appeal lacks merit)
- Rodriguez v. United States, 395 U.S. 327 (1969) (rejects requiring a defendant to specify points that would have been raised to obtain reinstated appellate rights)