Wright v. Van Patten

Background

A man charged with first-degree intentional homicide pleaded no contest to a reduced charge of first-degree reckless homicide and received a 25-year prison sentence. His trial lawyer was not physically in the courtroom for the plea hearing but participated by speakerphone. After sentencing he asked a state court to let him withdraw the plea, arguing his Sixth Amendment right to have counsel present was violated; the state court denied that motion and applied the usual test for lawyer mistakes.

Reasoning

The main question was whether the lawyer’s phone participation should be treated as a total denial of counsel, which would let a court presume prejudice and grant relief more easily. The Supreme Court explained that its prior cases do not clearly hold that phone participation equals total absence, and that the narrow exception to the usual rule applies only in very limited circumstances. Because the Court’s precedents give no clear answer, the federal habeas statute bars overturning the state court’s decision on collateral review.

Real world impact

The ruling leaves the state-court finding intact and makes it harder for prisoners to obtain federal habeas relief based on counsel appearing by phone at plea hearings. The Court did not decide whether phone participation is a good practice or would be allowed on direct appeal; that question is left for another day. This opinion resolves collateral-review limits more than the underlying constitutional question.

Dissents or concurrances

Justice Stevens joined the judgment and wrote separately, noting a drafting gap in earlier precedent and explaining why he accepts the result here without deciding the broader correctness of the state courts’ view.