Wisconsin ex rel. Wren v. Richardson
In brief
The Court declined review, so the Wisconsin court's procedural-bar decision remains in place and the Supreme Court did not decide the federal-law question.
- Where it stands
- Decided
Decided · June 1, 2020
- What it’s about
- The Supreme Court declined to review Wren’s case, leaving in place the Wisconsin court’s ruling that his claim of ineffective assistance by appellate counsel was procedurally barred.
- Who it affects
- The case concerns people whose lawyers allegedly fail to start a requested appeal, leaving them without appellate counsel. For example, an unrepresented defendant may face limits on later efforts to challenge a conviction.
Summary: written with AI from the case record.

What it's about
The dispute concerned whether that procedural bar was inconsistent with clearly established federal law when trial counsel’s failure to start a requested appeal left Wren without appellate counsel.
The dispute raised how procedural rules apply when a defendant says counsel's failure to begin an appeal caused delays in seeking postconviction relief.
Question presented
Whether the Wisconsin Court of Appeals' decision, which held that the petitioner's claim of ineffective assistance of appellate counsel was procedurally barred under State v. Escalona-Naranjo, 185 Wis. 2d 168, 517 N.W.2d 157 (1994), is contrary to, or involves an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States?
What the Court decided
What's next
The Supreme Court has finished its action on this docket. The Wisconsin court's result remains in effect.
Documents
Opinions
Key filings
Docket activity
New analysis added
AI analysis generated: Case Briefing
Case data updated: summary, question_presented, generation_metadata
Opinion added: Opinion
Brief added: Petition
More questions
- What did the Supreme Court rule in Wren v. Richardson?
- The Court declined to review the case. It did not decide whether Wisconsin's procedural bar conflicted with clearly established federal law.
- Who is affected by the Wren v. Richardson outcome?
- Defendants who say a lawyer failed to begin a requested appeal may be affected. Wisconsin's procedural-bar ruling remains in place for Wren's case.
- What happens next in Wren v. Richardson?
- The Supreme Court's docket action is finished. The Wisconsin court's decision remains in effect.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.