In Garza v Idaho, 586 U. S. ____ (2019), the U.S. Supreme Court held that the presumption of prejudice for Sixth Amendment purposes recognized in Roe v. Flores-Ortega applies regardless of whether a defendant has signed an appeal waiver. The case was decided by a vote of 6-3, with Chief Justice John G. Roberts Jr. and Justice Brett M. Kavanaugh siding with the Court’s “liberal” block.
