Access to the courts

1. In Garza v. Idaho, 586 U.S. 232 (2019), this Court held that counsel’s failure to file a requested notice of appeal constitutes per se ineffective assistance, resulting in presumed prejudice. Does a State functionally circumvent Garza when its procedural architecture mandates a post-plea motion as a strict jurisdictional prerequisite to appeal, thereby converting court-appointed counsel’s omission into an unreviewable, non-consensual constructive appellate waiver that permanently insulates Sixth Amendment claims from Article III review? 2. Under the Unconstitutional Conditions doctrine, does a state administrative agency execute an impermissible exaction when it indefinitely revokes a citizen’s physical transit privileges—their sole lawful means of accessing a state courthouse—and conditions the restoration of that fundamental benefit on the citizen’s affirmative waiver of their enumerated Fifth Amendment privilege against self-incrimination in parallel administrative proceedings? 3. Does a State violate the Fourteenth Amendment’s Due Process guarantee of meaningful court access when it mechanically enforces a jurisdictional filing deadline against an unrepresented litigant, while the State’s own hybrid digital-physical infrastructure creates a structural impossibility—specifically, the categorical exclusion of criminal litigants from the digital e-filing portal combined with a state-enforced administrative barrier to physical transit—thereby resulting in the state-created unavailability of the appellate forum?