Gideon v. Wainwright
Headline: Court overrules Betts v. Brady and holds states must provide lawyers to criminal defendants who cannot afford them, making it easier for poor people to get court-appointed counsel in serious criminal cases.
Holding: The Court held that the Sixth Amendment’s right to counsel is fundamental and, through the Fourteenth Amendment, requires states to appoint lawyers for indigent defendants in serious criminal cases.
- Requires states to appoint lawyers for poor defendants in serious criminal cases.
- Makes convictions without counsel more likely to be reversed on appeal.
- Increases state obligation to provide public defense for indicted defendants.
Summary
Background
Clarence Gideon was charged in a Florida state court with breaking and entering a poolroom; under Florida law the offense was treated as a felony. He had no money and no lawyer and asked the trial judge to appoint one. The judge refused, saying Florida appointed counsel only in capital cases. Gideon represented himself at trial, was convicted and sentenced to five years, then sought relief by habeas corpus after the Florida Supreme Court denied his petition without opinion.
Reasoning
The Court asked whether its earlier decision in Betts v. Brady should be reconsidered. Betts had held that a state’s refusal to appoint counsel for an indigent defendant did not always violate the Constitution’s guarantee of fair procedure. After reviewing earlier cases like Powell v. Alabama and considering the role of lawyers in our adversary system, the Court concluded the right to counsel is fundamental. It held the Sixth Amendment’s guarantee of counsel applies to the States through the Fourteenth Amendment, and that Betts was wrongly decided and must be overruled.
Real world impact
The ruling requires states to provide lawyers for defendants who cannot afford one in serious criminal prosecutions, so poor people will be more likely to receive court-appointed counsel. The Court reversed Gideon’s conviction and sent the case back to state court for further proceedings consistent with this decision. The decision changes the rule that states could refuse appointed counsel in noncapital cases.
Dissents or concurrances
Justices Clark and Harlan agreed with the judgment. Clark emphasized erasing the capital/noncapital distinction; Harlan agreed with overruling Betts but cautioned against mechanically importing all federal law onto the States.
Opinions in this case:
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