Garza v. Idaho

Facts of the Case

Petitioner Gilberto Garza, Jr., signed two plea agreements, each arising from state criminal charges and each containing a clause stating that Garza waived his right to appeal. Shortly after sentencing, Garza told his trial counsel that he wished to appeal. Instead of filing a notice of appeal, counsel informed Garza that an appeal would be “problematic” given Garza’s appeal waiver. After the time period for Garza to preserve an appeal lapsed, he sought state postconviction relief, alleging that his trial counsel had rendered ineffective assistance by failing to file a notice of appeal despite his repeated requests. The Idaho trial court denied relief, and the Idaho Court of Appeals affirmed. Also affirming, the Idaho Supreme Court held that Garza could not show the requisite deficient performance by counsel and resulting prejudice. In doing so, the court concluded that the presumption of prejudice recognized in, when trial counsel failed to file an appeal as instructed would not apply when the defendant has agreed to an appeal waiver. The United States Supreme Court granted Garza’s petition for certiorari review.

Question

May Courts of Appeals apply a presumption of unreasonableness to sentences that fall outside the range in the federal sentencing guidelines, so that district courts must justify below-guidelines sentences with a finding of extraordinary circumstances?

CONCLUSION

“The presumption of prejudice for Sixth Amendment purposes recognized in Roe v. Flores-Ortega , 528 U.S. 470 (2000), applies regardless of whether a defendant has signed an appeal waiver.In a 6–3 opinion authored by Justice Sonia Sotomayor, the Court held that Garza’s trial counsel had rendered ineffective assistance by failing to file a notice of appeal despite Garza’s repeated requests. Under Strickland v. Washington , 466 U.S. 668 (1984), a defendant alleging ineffective assistance of counsel must prove (1) “that counsel’s representation fell below an objective standard of reasonableness” and (2) that the deficiency was “prejudicial to the defense.” In Flores-Ortega , the Court held that “prejudice is presumed” in certain contexts, including when counsel “deprives a defendant of an appeal that he otherwise would have taken.” Garza’s appeal waivers—and appeal waivers generally—are not an absolute bar to all appellate claims. Indeed, some appeals fall outside the scope of the waiver, and there is always a possibility that the government might forfeit or breach the agreement of which the waiver is part. Given these scenarios, Garza could have pursued an appeal had his trial counsel acceded to his requests and filed a notice of appeal. By failing to do so, Garza’s counsel rendered ineffective assistance in violation of the Sixth Amendment.Justice Clarence Thomas filed a dissenting opinion, in which Justice Neil Gorsuch joined, and in which Justice Samuel Alito joined in part. The dissent opined that Garza’s counsel acted reasonably by declining to file an appeal on the grounds that doing so could jeopardize his plea bargain. The dissent characterized the majority’s holding as resulting in a “defendant-always-wins” rule that has no basis in the Court’s precedents or the Constitution.”

Case Information

Citation: 586 US (2019)
Granted: Jun 18, 2018
Argued: Oct 30, 2018
Decided: Feb 27, 2019
Case Brief: 2019