Garza v. Idaho

Gilberto Garza, Jr. signed a plea agreement that included a waiver of most appeal rights. After sentencing, he explicitly instructed his attorney to file a notice of appeal, but the attorney failed to do so, believing the waiver barred any appeal. Garza subsequently sought post-conviction relief, arguing that his lawyer's failure constituted ineffective assistance of counsel under the Sixth Amendment. The Idaho courts denied relief, holding that Garza could not show prejudice because no viable appeal existed. The case reached the U.S. Supreme Court, which considered whether the attorney's noncompliance with the client's directive to appeal automatically constitutes deficient performance, even when an appeal waiver is in place.

In a 6-3 decision authored by Justice Sotomayor, the Supreme Court held that when a defendant explicitly requests that an appeal be filed, the lawyer's failure to do so constitutes deficient performance per se, regardless of the appeal's potential merit or the existence of an appeal waiver. The presumption of prejudice is not overcome by the waiver, and the defendant is entitled to a new opportunity to appeal. The judgment of the Idaho courts was reversed and the case remanded.

Whether an attorney's failure to file a notice of appeal as expressly requested by the defendant automatically constitutes ineffective assistance of counsel under the Sixth Amendment, even when the defendant has signed an appeal waiver.

The ruling strengthened criminal defendants' Sixth Amendment protections by affirming that the decision to appeal rests with the client, not counsel. It clarified that appeal waivers do not relieve attorneys of the duty to follow a client's explicit instruction to appeal, thereby ensuring meaningful access to appellate review and reinforcing the ethical obligations of defense attorneys nationwide.