Morris v. Slappy
461 U.S. 1 (1983)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The Sixth Amendment right to counsel does not guarantee an indigent defendant a 'meaningful attorney-client relationship' with their appointed counsel, nor does it guarantee the defendant the right to be represented by a particular appointed attorney of their choice.
Facts:
- A woman was accosted, stalked, raped, sodomized, and robbed by respondent Slappy.
- Police apprehended Slappy shortly after the attack, finding the victim's jewelry on his person.
- The San Francisco Public Defender's Office was appointed to represent Slappy, and Deputy Public Defender Harvey Goldfine was assigned to the case.
- Goldfine represented Slappy at the preliminary hearing and conducted an extensive investigation in preparation for trial.
- Shortly before the trial was scheduled to begin, Goldfine was hospitalized for emergency surgery.
- Six days before the trial date, the Public Defender's Office assigned a senior trial attorney, Bruce Hotchkiss, to take over the case.
- Hotchkiss reviewed the case file, met with Slappy several times before trial, and stated to the court that he was prepared to proceed.
Procedural Posture:
- Slappy was convicted in San Francisco Superior Court (a state trial court) on five felony counts across two trials.
- The California Court of Appeal, First Appellate District (an intermediate appellate court), affirmed the convictions.
- The California Supreme Court (the state's highest court) denied review.
- Slappy filed a petition for a writ of habeas corpus in the United States District Court for the Northern District of California.
- The District Court denied the petition.
- Slappy, as the appellant, appealed to the United States Court of Appeals for the Ninth Circuit.
- The Court of Appeals reversed the District Court, finding a Sixth Amendment violation and ordering that the writ be granted unless Slappy received a new trial.
- Morris, the warden and petitioner, successfully petitioned the Supreme Court of the United States for a writ of certiorari.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Sixth Amendment's right to counsel require a state trial court to grant a continuance to allow a defendant to be represented by a specific, temporarily unavailable appointed counsel with whom the defendant allegedly has a 'meaningful relationship'?
Opinions:
Majority - Chief Justice Burger
No. The Sixth Amendment does not guarantee a 'meaningful relationship' between an accused and his counsel. Trial courts are granted broad discretion on matters of continuances to manage their dockets and ensure the efficient administration of justice. A continuance request may be denied unless the court's action is an 'unreasoning and arbitrary insistence upon expeditiousness in the face of a justifiable request for delay.' Here, the replacement counsel, Hotchkiss, was an experienced attorney who stated he was prepared for trial. Slappy's requests for a continuance were initially based on Hotchkiss's alleged lack of preparation, not a desire for Goldfine, and his later, mid-trial request for Goldfine was untimely and reasonably viewed as a 'transparent ploy for delay.' The Sixth Amendment guarantees competent representation, not a rapport with a particular appointed attorney.
Concurring - Justice Brennan
No. Concurring in the result, the denial of the continuance was proper because respondent Slappy's motion to be represented specifically by Goldfine was untimely, having been made for the first time mid-trial. However, the majority goes too far in summarily rejecting the constitutional significance of the attorney-client relationship. When a timely motion for a continuance is made to preserve an existing relationship with appointed counsel, a trial court should be required to balance the defendant's interest against the state's interest in efficiency. The majority unnecessarily creates a broad constitutional rule when the case could have been resolved on the narrow procedural ground that the motion was not made in a timely manner.
Concurring - Justice Blackmun
No. Concurring in the judgment, the Court of Appeals erred because Slappy did not make a timely request to postpone the trial until Goldfine could represent him. Absent such a request, the trial judge had no duty to inquire about Goldfine's availability. Like the majority's critique of the Court of Appeals, the majority itself has 'no occasion to consider' the broader Sixth Amendment issue. The Court's extensive dicta about the right to counsel and the concerns of victims are unnecessary, as the case is fully resolved by the fact that the defendant's request was untimely.
Analysis:
This decision significantly clarifies the scope of the Sixth Amendment right to appointed counsel, establishing that it is a right to effective assistance, not a right to a specific attorney or a positive personal relationship. By rejecting the 'meaningful attorney-client relationship' standard, the Court prioritized the administrative needs of the judiciary, granting trial judges substantial discretion in managing substitutions of counsel and denying continuances. The ruling reinforces the distinction between retained counsel, where choice is paramount, and appointed counsel, where competence is the constitutional floor. This precedent makes it much more difficult for indigent defendants to challenge the replacement of their appointed lawyer, provided the new lawyer is competent and has adequate time to prepare.
