Unanimous SCOTUS summary reversal of Ninth Circuit on right-of-appoint-counsel

A long day of meetings has meant it has taken me nearly all day to note today's notable Sixth Amendment ruling from the Supreme Court in Marshall v. Rodgers, No. 12-382 (S. Ct. Apr. 1, 2013) (available here).  The Rodgers ruling is a unanimous, per curiam summary reversal of the Ninth Circuit, and the start and end of the short SCOTUS opinion highlights its nuances:

Respondent Otis Lee Rodgers, challenging his state conviction, sought a writ of habeas corpus from the United States District Court for the Central District of California. He claimed the state courts violated his Sixth Amendment right to effective assistance of counsel by declining to ap- point an attorney to assist in filing a motion for a new trial notwithstanding his three prior waivers of the right to counseled representation. The District Court denied respondent’s petition, and he appealed to the Court ofAppeals for the Ninth Circuit, which granted habeasrelief.  678 F. 3d 1149, 1163 (2012).  Because the Court of Appeals erred in concluding that respondent’s claim issupported by “clearly established Federal law, as determined by the Supreme Court of the United States,” U. S. C. §2254(d)(1), its judgment must be reversed....

The Court expresses no view on the merits of the underlying Sixth Amendment principle the respondent urges.  And it does not suggest or imply that the underlying issue, if presented on direct review, would be insubstantial.  This opinion is instead confined to the determination that the conclusion of the California courts that there was no Sixth Amendment violation is not contrary to “clearly established Federal law, as determined by the Supreme Court of the United States.” §2254(d)(1).

The petition for a writ of certiorari and respondent’smotion to proceed in forma pauperis are granted.  The judgment of the United States Court of Appeals for the Ninth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion.