Yesterday, SCOTUS held in Garza v. Idaho that when a defendant’s lawyer does not file appeal on instruction of his client, because there is an appeal waiver in plea agreement, the defendant is to be presumed prejudiced for purposes of ineffective assistance of counsel claim. "...No appeal waiver serves as an absolute bar to all appellate claims." "Most fundamentally, courts agree that defendants retain the right to challenge whether the waiver itself was knowing and voluntary."