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.

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.

[3] The majority opinion, written by Sotomayor and joined by Roberts, Ginsburg, Breyer, Kagan, and Kavanaugh, held that Garza's trial counsel rendered ineffective assistance.

Part III of Thomas' dissent, joined by Gorsuch but not Alito, suggests the landmark Gideon v. Wainwright (1963, guaranteeing poor defendants a right to a lawyer in state criminal cases) was wrongly decided and should be overruled.

[4] Text of Garza v. Idaho 586 U.S. ___ (2019) is available from: Cornell Google Scholar Justia Oyez (oral argument audio) Supreme Court (slip opinion)