Marshall v. Rodgers
133 S. Ct. 1446
SCOTUS2013Background
- Rodgers challenged his California conviction via federal habeas corpus, alleging his Sixth Amendment right to counsel was violated when the trial court refused to appoint counsel to help file a motion for a new trial after multiple waivers of counsel.
- Rodgers repeatedly waived and later requested counsel; ultimately he proceeded to trial pro se and was convicted in 2003.
- Post-trial, Rodgers asked for counsel to assist with a new-trial motion; the court denied both oral and written requests.
- California appellate and state courts upheld the denial, relying on a totality-of-the-circumstances framework and Rodgers’s demonstrated competence and motives.
- The Ninth Circuit reversed the district court, holding that Rodgers’ right to appointed counsel was violated at the postwaiver stage; the Supreme Court granted certiorari to review under §2254(d)(1).
- The Supreme Court reversed the Ninth Circuit, concluding its reasoning misapplied clearly established federal law and remanded for proceedings consistent with this opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is post-waiver, preappeal new-trial motion a critical stage? | Rodgers | California | Assumed for analysis; not decided on the merits in this ruling. |
| May a trial judge deny post-waiver reappointment of counsel under California’s framework? | Rodgers | California | Ninth Circuit erred; California’s approach is not clearly established law that violates the Sixth Amendment. |
| Does California’s approach conflict with clearly established federal law on the right to counsel at critical stages? | Rodgers | California | No reversible conflict found; the Ninth Circuit’s reasoning was erroneous; judgment reversed. |
Key Cases Cited
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (self-representation is allowed with right to counsel at critical stages balanced by Faretta rights)
- Iowa v. Tovar, 541 U.S. 77 (U.S. 2004) (right to counsel at all critical stages, but can proceed without counsel if voluntary and intelligent)
- United States v. Cronic, 466 U.S. 648 (U.S. 1984) (presumed prejudice when counsel is unavailable at critical stages)
- Gideon v. Wainwright, 372 U.S. 335 (U.S. 1963) (right to counsel in criminal prosecutions)
- Yarborough v. Alvarado, 541 U.S. 652 (U.S. 2004) (general standard can supply clearly established law when no explicit rule exists)