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Wisconsin ex rel. Wren v. Richardson

Updated Sep 5, 2026

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.

Illustration for Wisconsin ex rel. Wren v. Richardson
Conceptual illustration · AI-generated

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

2

Docket activity

5
  • New analysis added

    Sep 5, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 5, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Sep 5, 2026 · Court records

  • Opinion added: Opinion

    Jun 1, 2020 · Court records

  • Brief added: Petition

    Mar 20, 2020 · Court records

More questions

3
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.

Checked Sep 5, 2026Methodology

Court records and filings

Reporting and analysis