Morris v. Slappy

Background

A defendant was charged with five felonies and originally represented by Deputy Public Defender Harvey Goldfine, who supervised the investigation. Goldfine was hospitalized shortly before trial and a senior Public Defender, Bruce Hotchkiss, was assigned six days before the scheduled start. The defendant repeatedly complained that his replacement had too little time to prepare, refused to cooperate with counsel, and was convicted in two trials. A federal appeals court ordered relief, announcing a new rule that the Sixth Amendment guarantees a defendant a "meaningful attorney-client relationship."

Reasoning

The core question was whether denying a short continuance so the hospitalized attorney could return violated the Constitution’s right to a lawyer (Sixth Amendment). The Supreme Court found the trial record showed Hotchkiss had reviewed the case, met with the defendant, and told the judge a further delay would not help. The Court held the defendant’s complaints were late and inconsistent, and that the appeals court erred in creating a new constitutional right to a "meaningful" relationship with appointed counsel. The majority emphasized trial judges need broad discretion to manage schedules and noted the victim’s interest in avoiding repeated trials.

Real world impact

The decision removes the new rule the appeals court announced and affirms that trial judges may deny last-minute continuances when replacement public defenders say they are ready. It makes it harder for defendants to secure a delay simply because their originally appointed lawyer is temporarily unavailable, while preserving review for clear abuses of discretion.

Dissents or concurrances

Two concurring opinions agreed with reversal but differed on scope: one urged more protection for an accused’s relationship with counsel, while another favored a narrower, timing-based ruling.