Gideon v. Wainwright
372 U.S. 335 (1963)
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Rule of Law:
The Sixth Amendment's guarantee of a right to counsel is a fundamental and essential right made obligatory upon the states by the Due Process Clause of the Fourteenth Amendment. States must provide counsel to indigent defendants in all felony prosecutions.
Facts:
- Clarence Earl Gideon was charged in a Florida state court with the felony of breaking and entering a poolroom with the intent to commit a misdemeanor.
- Appearing in court without funds, Gideon was unable to hire a lawyer to represent him.
- Gideon requested that the trial court appoint an attorney for him.
- The trial judge denied his request, explaining that under Florida law, counsel could only be appointed for indigent defendants in capital cases.
- Forced to represent himself, Gideon conducted his own defense at trial.
Procedural Posture:
- Clarence Earl Gideon was tried before a jury in a Florida state trial court.
- The jury returned a verdict of guilty, and the court sentenced Gideon to five years in the state prison.
- While imprisoned, Gideon filed a petition for a writ of habeas corpus in the Supreme Court of Florida, the state's highest court, arguing his conviction was unconstitutional.
- The Florida Supreme Court denied Gideon's petition for habeas corpus without issuing an opinion.
- Gideon, proceeding in forma pauperis, petitioned the United States Supreme Court for a writ of certiorari.
- The U.S. Supreme Court granted certiorari to review the Florida Supreme Court's decision and to reconsider its holding in Betts v. Brady.
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Issue:
Does a state court's refusal to appoint counsel for an indigent defendant charged with a felony violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Black
Yes. The refusal to appoint counsel for an indigent defendant in a state felony trial violates the Due Process Clause of the Fourteenth Amendment. The Court explicitly overrules its prior decision in Betts v. Brady, holding that the Sixth Amendment's guarantee of counsel is a fundamental right essential to a fair trial. Reasoning that an average person lacks the skill to defend themselves adequately, the Court concludes that in an adversarial system, a defendant cannot be assured a fair trial without legal representation. The Court incorporates this Sixth Amendment right to the states, arguing that governments spend vast sums on prosecutors, and defendants with money always hire lawyers, demonstrating that legal counsel is a necessity, not a luxury, for achieving a fair outcome.
Concurring - Justice Clark
Yes. The Constitution makes no distinction between capital and noncapital cases regarding the procedural protections required. The Fourteenth Amendment requires due process for the deprivation of 'liberty' just as it does for the deprivation of 'life,' and there is no logical basis for affording a different quality of process based on the severity of the potential punishment. Therefore, the right to appointed counsel must apply in all serious criminal cases, not just capital ones.
Concurring - Justice Douglas
Yes. While joining the Court's opinion, Justice Douglas writes separately to reiterate his long-held view that the Fourteenth Amendment incorporates the entire Bill of Rights, making all its protections applicable to the states. He argues that the rights protected against state action by the Fourteenth Amendment are not 'watered-down versions' of the rights guaranteed against federal encroachment. The decision correctly applies the Sixth Amendment's right to counsel to the states.
Concurring - Justice Harlan
Yes. The 'special circumstances' rule established in Betts v. Brady should be overruled because it has been steadily eroded to the point that the mere existence of a serious criminal charge now constitutes a special circumstance requiring counsel. It is time to formally abandon the rule for all serious offenses, making explicit what has long been foreshadowed in the Court's decisions. However, he cautions that incorporating a right from the Bill of Rights onto the states does not mean that the entire body of federal law associated with that right is automatically applied in full sweep to the states.
Analysis:
This landmark decision fundamentally altered the landscape of criminal procedure in the United States by establishing an absolute right to counsel for indigent defendants in state felony cases. By explicitly overruling Betts v. Brady, the Court rejected the unpredictable case-by-case 'special circumstances' approach and created a clear, bright-line rule. The ruling had an immediate and massive practical impact, requiring states to establish and fund public defender systems to ensure compliance with the new constitutional mandate. Gideon is a cornerstone of modern criminal defense rights and a key example of the Supreme Court's use of selective incorporation to apply the Bill of Rights to the states.
