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Garza v. Idaho

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Supreme Court of the United States
Garza v. Idaho
Term: 2018
Important Dates
Argument: October 30, 2018
Decided: February 27, 2019
Outcome
Reversed and remanded Idaho Supreme Court
Vote
6-3
Majority
Chief Justice John G. Roberts • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh
Dissenting
Clarence Thomas • Samuel Alito • Neil Gorsuch

Garza v. Idaho is a case argued before the Supreme Court of the United States on October 30, 2018, during the court's 2018-2019 term. The case concerned a trial counsel’s responsibilities in filing a notice of appeal.

In a 6-3 ruling, the court reversed and remanded the decision of the Idaho Supreme Court, holding that "Flores-Ortega’s presumption of prejudice applies regardless of whether a defendant has signed an appeal waiver."[1][2]

HIGHLIGHTS
  • The case: In 2015, Gilberto Garza, Jr., signed two plea agreements relating to charges of aggravated assault and possession of a controlled substance with intent to distribute. As part of his plea agreements, he waived his right to appeal. Garza later asked his attorney to appeal the convictions, but his attorney did not. Garza then filed petitions for post-conviction relief because his attorney did not file the appeals. The Idaho Supreme Court held that Garza’s attorney was allowed to ignore Garza’s request to file the appeals.
  • The issue: Does the "presumption of prejudice" recognized in Roe v. Flores-Ortega, 528 U.S. 470 (2000), apply where a criminal defendant instructs his trial counsel to file a notice of appeal but trial counsel decides not to do so because the defendant's plea agreement included an appeal waiver?[3]
  • The outcome: The court reversed and remanded the decision of the Idaho Supreme Court, holding that "Flores-Ortega’s presumption of prejudice applies regardless of whether a defendant has signed an appeal waiver."[2]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • February 27, 2019: U.S. Supreme Court reversed and remanded the decision of the Idaho Supreme Court
    • October 30, 2018: Oral argument
    • June 18, 2018: U.S. Supreme Court agreed to hear case
    • January 23, 2018: Petition filed with U.S. Supreme Court
    • November 6, 2017: The Idaho Supreme Court held that Garza’s attorney was not ineffective in failing to appeal his convictions.

    Background

    In 2015, Gilberto Garza, Jr., signed two plea agreements relating to charges of aggravated assault and possession of a controlled substance with intent to distribute. As part of his plea agreements, he waived his right to appeal. Garza later asked his attorney to appeal the convictions, but his attorney did not. His attorney chose not to file the appeals because he said Garza waived his right to appeal. Garza then filed petitions for post-conviction relief because his attorney did not file the appeals.[4]

    According to Oyez, “Under Roe v. Flores-Ortega, 528 U.S. 470 (2000), criminal defendants have a Sixth Amendment right to ‘reasonably effective’ legal assistance. A defendant claiming ineffective assistance of counsel must show: (1) that counsel’s representation was deficient; and (2) that counsel’s deficient performance prejudiced the defendant. Generally, counsel’s failure to file an appeal at a criminal defendant’s request is professionally unreasonable and therefore deficient, and most federal circuit courts interpret Flores-Ortega to mean that attorneys are ineffective when they do not file an appeal if the clients requested it, regardless of whether the defendants had waived their rights.”[5]

    The Idaho Supreme Court held that Garza’s attorney was allowed to ignore Garza’s request to file the appeals. Garza appealed to the U.S. Supreme Court, and the court agreed to hear the case on June 18, 2018.[4]

    Question presented

    The petitioner presented the following question to the court:[3]

    Question presented:
    • Does the "presumption of prejudice" recognized in Roe v. Flores-Ortega, 528 U.S. 470 (2000), apply where a criminal defendant instructs his trial counsel to file a notice of appeal but trial counsel decides not to do so because the defendant's plea agreement included an appeal waiver?

    Audio

    • Audio of oral argument:[6]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Decision

    Justice Sonia Sotomayor delivered the 6-3 opinion of the court. The court reversed and remanded the decision of the Idaho Supreme Court, holding that "Flores-Ortega’s presumption of prejudice applies regardless of whether a defendant has signed an appeal waiver."[1][2]

    Opinion

    In her opinion for the court, Justice Sotomayor, who was joined by Chief Justice John G. Roberts and Justices Ruth Bader Ginsburg, Stephen Breyer, Elena Kagan, and Brett Kavanaugh, wrote,

    “ We hold today that the presumption of prejudice recognized in Flores-Ortega applies regardless of whether a defendant has signed an appeal waiver. This ruling follows squarely from Flores-Ortega and from the fact that even the broadest appeal waiver does not deprive a defendant of all appellate claims. Accordingly where, as here, an attorney performed deficiently in failing to file a notice of appeal despite the defendant’s express instructions, prejudice is presumed 'with no further showing from the defendant of the merits of his underlying claims.' See Flores-Ortega, 528 U. S., at 484.[7] ”

    Dissenting opinion

    Justice Clarence Thomas filed a dissenting opinion, in which Justice Neil Gorsuch joined and in which Justice Samuel Alito joined as to Parts I and II. Justice Thomas wrote,

    “ Petitioner Gilberto Garza avoided a potential life sentence by negotiating with the State of Idaho for reduced charges and a 10-year sentence. In exchange, Garza waived several constitutional and statutory rights, including 'his right to appeal.' App. to Pet. for Cert. 44a, 49a. Despite this express waiver, Garza asked his attorney to challenge on appeal the very sentence for which he had bargained. Garza’s counsel quite reasonably declined to file an appeal for that purpose, recognizing that his client had waived this right and that filing an appeal would potentially jeopardize his plea bargain. Yet, the majority finds Garza’s counsel constitutionally ineffective, holding that an attorney’s performance is per se deficient and per se prejudicial any time the attorney declines a criminal defendant’s request to appeal an issue that the defendant has waived. In effect, this results in a 'defendant-always wins' rule that has no basis in Roe v. Flores-Ortega, 528 U. S. 470 (2000), or our other ineffective-assistance precedents, and certainly no basis in the original meaning of the Sixth Amendment. I respectfully dissent.[7] ”

    Text of the opinion

    • Read the full opinion here.

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 Supreme Court of the United States, "Garza v. Idaho," accessed September 29, 2018
    2. ↑ 2.0 2.1 2.2 2.3 2.4 United States Supreme Court, "Garza v. Idaho," Opinion, February 27, 2019 Cite error: Invalid <ref> tag; name "opinion" defined multiple times with different content
    3. ↑ 3.0 3.1 Supreme Court of the United States, "17-1026 Garza v. Idaho," accessed September 28, 2018
    4. ↑ 4.0 4.1 4.2 SCOTUSblog, "Garza v. Idaho," accessed September 29, 2018
    5. ↑ Oyez, "Garza v. Idaho," accessed October 5, 2018
    6. ↑ Supreme Court of the United States, Garza v. Idaho, argued October 30, 2018
    7. ↑ 7.0 7.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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