Hamilton v. Alabama

Background

A man was sentenced to death after being charged with breaking into a dwelling at night with intent to ravish. He appealed, arguing he had no lawyer when he was arraigned on the later indictment. Alabama courts noted the right to counsel at arraignment under state and federal law but did not reach the claim on appeal because trial minute entries suggested a lawyer had been present. The man then sought relief through coram nobis in Alabama, which denied relief for lack of proof he was disadvantaged, and the case reached this Court.

Reasoning

The central question was whether an accused in a capital case in Alabama must have a lawyer at arraignment, a stage when key defenses must be raised. The Court explained that under Alabama law arraignment is a critical stage where defenses like insanity or motions to quash must be made or may be lost. Relying on prior decisions about the need for counsel in capital cases, the Court held that the absence of counsel at this stage prevents a fair opportunity to know and assert defenses, and that prejudice cannot be reliably measured after the fact. Because only counsel could have fully protected the defendant’s rights at arraignment, the Court reversed the conviction.

Real world impact

The ruling means that, at least in Alabama capital cases, courts must ensure an accused has legal representation at arraignment so important defenses are not lost. The opinion notes that arraignment has different consequences in other States, so the decision is grounded in Alabama’s procedural context.