Hadley v. Alabama

Background

George Hadley, a defendant in Alabama, filed his certified transcript three days after the state’s 60-day deadline and paid for the transcript himself at trial but lacked counsel on appeal. The Alabama Court of Criminal Appeals dismissed his appeal as untimely and the Alabama Supreme Court affirmed, though three state justices dissented. Alabama's Rule 48 and earlier state cases had allowed late transcript filings for indigent defendants.

Reasoning

The central question raised was whether a State may effectively give indigent people more time or more leeway to file appeal materials than people who can pay. Justice Douglas, writing in dissent from the denial of review, argued that treating people differently because of wealth is a suspect classification and that a State may not grant appellate review in a way that discriminates against the poor or the rich. He said that—even though there is no constitutional right to an appeal—the State cannot structure appellate review to disadvantage people who paid for their transcripts.

Real world impact

Because the Court denied the petition, Alabama’s practice remains in place for now, meaning indigent defendants may benefit from leniency that wealthier defendants do not. Hadley’s dismissal stays effective unless a future court takes the issue for full review. The decision as issued is a denial of review, not a final nationwide ruling on the constitutional question.

Dissents or concurrances

Justice Douglas would have granted review and heard argument, emphasizing that equal protection applies to both rich and poor and noting similar concerns in other cases where he dissented.