In Halbert v. Michigan (2005) 545 U.S. 605, the United States Supreme Court held that the State of Michigan's post-plea requirement that defendants obtain leave before being allowed to appeal violated the due process and equal protection clauses. (Id. at p. 610.) Halbert involved a rule that defendants in plea cases themselves submit applications for leave to appeal to Michigan's intermediate appellate court. (Id. at p. 612.) If the Court of Appeals granted leave, it then appointed appellate counsel. (Id. at pp. 612-613.) Michigan defendants in plea cases automatically received the benefit of appellate counsel only when the prosecution sought to appeal or the defendant's sentence exceeded the upper limit of the minimum sentence range. (Id. at p. 613.) To obtain leave to appeal, defendants needed to "submit five copies of the application for leave to appeal 'stating the date and nature of the judgment or order appealed from; concisely reciting the appellant's allegations of error and the relief sought; and setting forth a concise argument . . . in support of the appellant's position on each issue.'" (Halbert, supra, 545 U.S. at p. 622, quoting Kowalski v. Tesmer (2004) 543 U.S. 125, 141.) The Michigan Court of Appeals reviewed these pro se applications, and summarily denied many on the basis of "lack of merit in the grounds presented . . . ." (Id. at pp. 612-613.) Finding the leave requirements onerous for indigent defendants, the United States Supreme Court held the Michigan rule unconstitutional. (Id. at p. 622.)