Reminder to Counsel: Representation Includes Filing Petitions for Certiorari


According to the fine folks at SCOTUSBlog, the U.S. Supreme Court grants certiorari in approximately 80 cases each year. Nearly 8,000 litigants petition the Court for review. And so, the odds that the Supreme Court will grant certiorari in any particular case are extremely poor—somewhere around a 1% chance, according to one estimate. Those chances are even lower if the petitioner must file the petition in forma pauperis, i.e., a motion for permission to file without paying the Court’s filing fee. This can leave counsel appointed under the Criminal Justice Act to represent criminal defendants on appeal feeling like filing a petition for certiorari is a waste of time even when the client wishes to do so.

In an unpublished order, in United States v. Givhan, the Sixth Circuit reminded all CJA appointees that, even though counsel need not file a frivolous petition for certiorari, they must follow a certain protocol before they may withdraw. Counsel must inform the defendant of his or her right to file a petition and file a certification that, after reviewing the records, “there exist no non-frivolous grounds for appeal.” In Givhan’s counsel did not follow this required procedure.

The Sixth Circuit’s reminder raises the question: Why not file a petition for certiorari? If the Supreme Court can change the law, are there any claims that are non-frivolous? Sometimes writing a certification takes as much time to draft as a petition for certiorari. Plus, who knows? Maybe you can be like the defense lawyers who have prevailed against all odds before. The modern Commerce Clause jurisprudence would not be what it is without the efforts of two Federal Public Defenders who happened to catch the Supreme Court’s eye in United States v. Lopez.


shrug GIF
https://media.giphy.com/media/r8WtY1wSWSZTa/giphy.gif

No comments: