Gideon v. Wainwright

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Gideon v. Wainwright
Supreme Court of the United States
Argued January 15, 1963 Decided March 18, 1963
Full case name: Clarence Earl Gideon v. Louie L. Wainwright, Corrections Director Citations: 372 U.S. 335; 83 S. Ct. 792; 9 L. Ed. 2d 799; 1963 U.S. LEXIS 1942; 23 Ohio Op. 2d 258; 93 A.L.R.2d 733; OYEZ Prior history: Defendant convicted, Bay County, Florida Circuit Court (1961); habeas petition denied w/o opinion, sub. nom. Gideon v. Cochrane, 135 So. 2d 746 (Fla. 1961) Subsequent history: On remand, 153 So. 2d 299 (Fla. 1963); defendant acquitted, Bay County, Florida Circuit Court (1963)
Holding
The Sixth Amendment right to counsel is a fundamental right applied to the states through the Fourteenth, and requires that indigent criminal defendants be provided counsel at trial. Supreme Court of Florida reversed.
Court membership
Chief Justice: Earl Warren Associate Justices: Hugo Black, William O. Douglas, Tom C. Clark, John Marshall Harlan II, William J. Brennan, Potter Stewart, Byron White, Arthur Joseph Goldberg
Case opinions
Majority by: Black Concurrence by: Douglas Concurrence by: Harlan
Laws applied
U.S. Const. amends. VI, XIV

Gideon v. Wainwright, 372 U.S. 335 (1963), is a landmark case in United States Supreme Court history. In the case, the Supreme Court unanimously ruled that state courts are required by the Sixth and Fourteenth Amendments to the Constitution to provide lawyers in criminal cases for defendants unable to afford their own attorneys.

[edit] Background

The Supreme Court Powell v. Alabama, 287 U.S. 45 (1932), the famous case of the Scottsboro Boys, that the right to counsel was essential to the safeguarding of American freedoms, but left it up to the states just how far this right extended. In Betts v. Brady, 316 U.S. 455 (1942), the Court modified this doctrine slightly, ruling that whether or not a lawyer was required would depend on the circumstances of each case. Specifically, the Court focused on a case-by-case determination of whether the lack of representation affected a denial of due process, rendering the trial unfair. Over the next twenty years, the Court heard several more cases, and in all of them ruled that in fact a lawyer was required. Due to the difficulty of proving the high standard of a due process violation, nearly all such cases involved the death penalty. This view hadn't changed by the early 1960s.

In 1961, Clarence Earl Gideon had been charged with burglary for breaking into a pool hall in Panama City Bay County, Florida and taking money from the vending machines. He appeared in court too poor to afford counsel, whereupon the following conversation took place:

The COURT: Mr. Gideon, I am sorry, but I cannot appoint Counsel to represent you in this case. Under the laws of the State of Florida, the only time the Court can appoint Counsel to represent a Defendant is when that person is charged with a capital offense. I am sorry, but I will have to deny your request to appoint Counsel to defend you in this case.

GIDEON: The United States Supreme Court says I am entitled to be represented by Counsel.

Gideon had been forced therefore to act as his own counsel, and conducted a defense of himself in court, emphasizing his innocence in the case. Nevertheless, the jury returned a guilty verdict, sentencing him to serve five years in the state penitentiary. From his prison cell, and making ample use of the prison library, Gideon appealed to the U.S. Supreme Court based on the fact that he had been denied counsel and therefore his Fourteenth Amendment rights had been violated without due process of law. The court assigned him a prominent Washington, D.C., attorney, Abe Fortas (later a Supreme Court justice from 1965–1969) of the law firm of Arnold & Porter.

[edit] Decision

The decision was announced on 18 March 1963; the opinion of the Court was delivered by Justice Hugo Black.

In it, the court specifically praised its previous ruling in Powell v. Alabama, and overruled Betts v. Brady, which allowed selective application of the Sixth Amendment right to counsel to the states, itself previously binding only in Federal cases. Instead, the court held that the right to the assistance of counsel was a fundamental right, essential for a fair trial, thereby emphasizing the procedural safeguards which were needed for due process of law. In this sense, the court ruled specifically that no one, regardless of wealth, education or class, should be charged with a crime and then be forced to face his accusers in court without the guidance of counsel. All of the other justices concurred in the judgment.

The court remanded the case to the Supreme Court of Florida for "further action not inconsistent with this decision." Gideon was then retried: represented by appointed counsel in this second trial, he was acquitted.

Gideon v. Wainwright was one of a series of Supreme Court decisions which confirmed the right of defendants in criminal proceedings to counsel during trial, on appeal, and in the subsequent cases of Massiah v. United States 377 U.S. 201 (1964) and Miranda v. Arizona 384 U.S. 436 (1966), even during police interrogation.