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This January 13, 2005 article discusses the case of Kowalski v. Tesmer. According to this article, "Last month, in a little-noticed decision, the United States Supreme Court dealt a serious blow to indigent defendants around the country. Kowalski v. Tesmer, though seemingly a case about standing (the majority refused to decide the merits of the case by deciding that the lawyers who brought it weren't properly before the court), functionally allows the state of Michigan to continue the practice of denying appellate lawyers to most poor people who plead guilty."