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Gideon v. Wainwright

Gideon v. Wainwright 372 US 335 (1963) is a landmark case in United States Supreme Court history. In the latter half of the twentieth century, Gideon v. Wainwright represents an important step in Constitutional law made by the Supreme Court in applying the Sixth Amendment (right to counsel) and the Fourteenth Amendment (no person shall be deprived of life, liberty, or property without due process of law) to all citizens.

Background

The Supreme Court had earlier ruled in Powell v. Alabama[?] 287 US 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 US 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. Over the next twenty years, the Court heard several more cases, and in all of them ruled that in fact a lawyer was required. This view had not changed by the early 1960s.

The Case

In 1961, Clarence Earl Gideon had been accused of breaking into a pool hall in Florida and taking money from the vending machines. He appeared in court to 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.

The DEFENDANT: 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 jail 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, DC, attorney, Abe Fortas (a Supreme Court justice from 1965-1969) as counsel.

The 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, itself previously binding only in Federal cases. Instead, the court held that the right to 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.

The court remanded the case to the Supreme Court of Florida for "further action not inconsistent with this decision." Gideon was then retried by the state of Florida and acquitted. Gideon v. Wainwright is the first in a series of Supreme Court decisions which allowed defendants counsel during trial, appeal and even during police interrogation. It is a decision emblematic of the Court under Chief Justice Earl Warren, whose tenure is marked by decisions that expand the scope of rights granted to U. S. citizens. In addition, the Warren Court is generally noted as judicially activist; that is, willing to turn against precedent and break new ground in U.S. law.