Garza v. Idaho, 586 U.S. ___, 139 S. Ct. 738 (2019), was a case in which the United States Supreme Court held that the presumption of prejudice for Sixth Amendment purposes applies regardless of whether a defendant has waived the right to appeal.^[1]

In 2015, petitioner Gilberto Garza, Jr. signed two plea agreements which required him to waive his right to appeal.^[2] After sentencing, Garza informed his trial counsel of his wish to appeal. Due to the appeal waivers signed by Garza, counsel declined to file a notice of appeal. After the time period to file an appeal lapsed, Garza filed a petition for state post-conviction relief on the basis of ineffective assistance of counsel. The trial court denied relief and the Idaho Court of Appeals affirmed. The Idaho Supreme Court affirmed, concluding that the presumption of prejudice as recognized in Roe v. Flores-Ortega does not apply when the defendant has agreed to waive the right to appeal.

Amir Ali presented oral argument for Garza before the Supreme Court, with Ken Jorgensen and Alon Kedem representing the State of Idaho and United States, respectively. The Court announced its judgment in favor of the petitioner on February 27, 2019, with the court reversing and remanding by a vote of 6–3.^[3]

• 2018 term opinions of the Supreme Court of the United States