Most of what Justice Ginsberg says at page 14-5 in Halbert v. Michigan (slip op.) comes from Kowalski. I don't remember any prior opinion describing: "Appeals by defendants convicted on their pleas [of guilty] may involve 'myriad and often complicated' substantive issues, and may be 'no less complex than other appeals.'" Yet, that is now the law. This is not a new phenomenon, but Kowlaski does not even appear in the US Reports yet. So, timewise, it may be a record for the catapulting of a dissenting view.

Isn't everyone who applied for review by the Michigan Court of Appeals without appointed counsel after request since 1994 entitled to the same relief? Looks like those courts will be busy reviewing a lot of cases for the second time. Wonder how many of them will result in Anders briefs once they get an attorney to assist?

Anyone think the decision would have been different if the amendment to the Michigan Constitution had provided: "an appeal by an accused who pleads guilty or nolo contendere shall be by leave of the court, which may be denied for any reason or not reason at all"?