What US Supreme Court case gave the right to counsel for indigent defendants in state criminal cases?

Answer 1

Gideon v. Wainwright, 372 US 335 (1963)

Answer

Gideon v. Wainwright is a landmark US Supreme Court case that incorporated the Sixth Amendment right to counsel in criminal proceedings to the states via the Fourteenth Amendment Due Process Clause. In this case, the Court ruled emphatically that indigent defendants were entitled to court-appointed lawyers at critical stages of prosecution, including arraignment and trial.

An earlier case, Powell v. Alabama, 287 US 45 (1932) had already extended that right to state defendants in capital (death penalty) cases, but the Supreme Court later allowed the states to exercise case-by-case discretion with regard to providing attorneys for other serious criminal offenses in Betts v. Brady, 316 US 455 (1942).

Explanation

Clarence Earl Gideon was a drifter who had been homeless most of his life. He developed a record of petty crime as a juvenile, and continued as an adult habitual offender. Gideon had been convicted and incarcerated in Texas and Missouri prisons on charges of robbery, burglary, larceny, escape, and theft. Gideon was nearly illiterate, poor, and had little formal education.

Sometime between midnight and 6:00 am on June 3, 1961, someone broke into Ira Strickland's Bay Harbor Pool Room, near Panama City, FL. The burglar smashed a window, pried open the cigarette and soda machines, and left with approximately $5.00 in change, and at least one bottle of wine.

Henry Cook, who lived in the neighborhood, told police he had seen Clarence Earl Gideon exit the Pool Hall around 5:30 am, carrying a bottle of wine. The police located Gideon, found change in his pockets, and arrested him on charges of breaking and entering with intent to commit petty larceny, a felony.

When Gideon appeared before the Florida court, he requested a court-appointed attorney, but the judge denied his request because Florida law only required the state provide counsel for capital offenses. The court record shows Gideon objected on the grounds that the Supreme Court said he had a Sixth Amendment right to legal representation. The judge refused to accommodate Gideon's request, so the defendant was forced to represent himself (pro se).

Although Gideon attempted to defend himself, he was unable to discredit any witnesses or weaken the Prosecution's case. As a result, he was found guilty and sentenced to the maximum penalty - five years in prison. Gideon began serving his sentence in August 1961.

Using the prison library for reference, Gideon filed a writ of habeas corpus with the Florida Supreme Court, but his petition was denied. He then wrote a six-page letter to the Supreme Court on prison letterhead, seeking to appeal against the Secretary to the Florida Department of Corrections, Louie L. Wainwright. The Supreme Court granted certiorari, and appointed future Supreme Court justice Abe Fortas as Gideons counsel.

Supreme Court Decision

In a unanimous 9-0 decision, the Court held that its opinion in Betts v. Brady, (1942), which allowed the states to apply the Sixth Amendment selectively under the "special circumstances" doctrine, was unconstitutional. Betts essentially said the appointment of counsel was not a fundamental right; in Gideon v. Wainwright, the Court overturned the earlier precedent and asserted that "Lawyers are necessities, not luxuries." The ruling in this case incorporated the Right to Counsel Clause to the states via the Fourteenth Amendment Due Process clause, finally establishing that even indigent defendants deserved the benefit of legal representation.

Gideon was not the first case in which the Warren Court expressed doubt about the ruling in Betts. Reid v. Covert,354 US 1 (1957) foreshadowed the decision to enforce the Bill of Rights against entities previously exempt from protecting certain fundamental rights. In Covert, the Supreme Court held that treaties with other countries did not revoke constitutional protections for US citizens, when the Court held that military spouses could not be convicted under military jurisdiction (except under certain exceptional circumstances), and could not be deprived of their constitutional rights, even if living overseas.

Another case earlier case, Ferguson v. Georgia, 365 US 570 (1961), overturned a contradictory Georgia law that denied people deemed incompetent to testify on their own behalf "effective assistance of counsel."

In Gideon, the Court essentially held that all laymen (non-lawyers) were incompetent to defend themselves at trial:

"The right to be heard would be, in many cases, of little avail if it did not comprehend the right to be heard by counsel. Even the intelligent and educated layman has small and sometimes no skill in the science of law. If charged with crime, he is incapable, generally, of determining for himself whether the indictment is good or bad. He is unfamiliar with the rules of evidence. Left without the aid of counsel, he may be put on trial without a proper charge, and convicted upon incompetent evidence, or evidence irrelevant to the issue or otherwise inadmissible. He lacks both the skill and knowledge adequately to prepare his defense, even though he have a perfect one. He requires the guiding hand of counsel at every step in the proceedings against him. Without it, though he be not guilty, he faces the danger of conviction because he does not know how to establish his innocence."

Gideon's conviction was overturned, and the case was remanded to the Florida Supreme Court so they could make arrangements for a new trial. Gideon was represented at the second trial by attorney W. Fred Turner, who successfully discredited the prosecution's witnesses, demonstrating there was no evidence against his client. The jury deliberated only an hour before acquitting Gideon of the charges.

Epilogue

The state of Florida immediately complied with the Supreme Court's decision, and hired public defenders to work in its 16 state circuit courts.

Gideon v. Wainwright, (1963) set the stage for later cases that expanded constitutional protections for the accused. For example, Miranda v. Arizona, (1966), provided that law enforcement officials must explicitly notify those in custody of their rights under the Fifth and Sixth Amendments.

In 1972, the Court held that the Sixth Amendment right of indigent and low-income defendants to receive court-appointed counsel applied to every case of felony offense, as well as to any case in which the defendant is actually incarcerated, even if the crime is classified as a misdemeanor, per Scott v. Illinois,440 U.S. 367 (1979).

In 2002, the Supreme Court further extended the right to counsel to any case where imprisonment is a possibility, even if the sentence is suspended, in Alabama v. Shelton, 535 US 654 (2002).

For more information, see Related Questions, below.

Answer 2

In re Gault, 387 U.S. 1 (1967)

In Gault, the Supreme Court extended the Sixth Amendment right to court-appointed counsel to indigent juveniles.

Answer 3

Scott v. Illinois, 440 U.S. 367 (1979)

Scott represented a broadening, not limitation, of the standard set in Gideon v. Wainwright. Prior to this case, only felony defendants were given the right to court-appointed counsel, but indigent people guilty of misdemeanors, even those whose crimes were punishable by incarceration, were denied the right to counsel unless they could somehow acquire the services of a private attorney.

In Scott, the Court held that the Sixth Amendment right of indigent and low-income defendants to receive court-appointed counsel applied to every case of felony offense, as well as to any charge resulting in a sentence, even if the crime is classified as a misdemeanor.

In 2002, the Supreme Court further extended the right to court-appointed counsel to any case where imprisonment is a possibility, even if the sentence is suspended, in Alabama v. Shelton, 535 US 654 (2002).

For more information, see Related Questions, below.

Answer 4

Gideon v. Wainwright (1963) is the case that the United States supreme court held that the state must provide counsel to those who cannot afford to hire one for themselves.

Answer 5

One applicable case is Scott v. Illinois, 440 U.S. 367 (1979).

Answer 6

Gideon v. Wainwright