Frank Cooks, Jr., Appellant v. the State of Texas

Summary

The Court held that the 30‑day period for filing a motion for new trial is a critical stage of a criminal proceeding that triggers the Sixth Amendment right to counsel. It affirmed the presumption of adequate representation during that stage, but allowed that the presumption can be rebutted and any deprivation is subject to harmless‑error analysis, finding no prejudice in this case.