Hamilton v. Alabama
368 U.S. 52 (1961)
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Rule of Law:
The Sixth Amendment right to counsel, applicable to the states through the Fourteenth Amendment, requires the appointment of counsel for an indigent defendant in a capital case at the arraignment, as it is a critical stage of the criminal proceedings. The denial of counsel at such a critical stage constitutes a per se constitutional violation, requiring reversal without a specific showing of prejudice.
Facts:
- Petitioner Hamilton was charged in Alabama with breaking and entering a dwelling at night with intent to ravish, a capital offense.
- At his arraignment, a formal court proceeding where charges are read, Hamilton did not have legal counsel present.
- Hamilton entered a plea of not guilty to the charges.
- Under Alabama law at the time, certain defenses and motions had to be raised at the arraignment or were otherwise lost.
- These included the defense of insanity and pleas in abatement, such as motions to quash the indictment due to improper grand jury composition.
Procedural Posture:
- Hamilton was convicted of a capital offense and sentenced to death in an Alabama trial court.
- Hamilton appealed to the Supreme Court of Alabama, which affirmed the conviction, declining to review his claim of denial of counsel because it would require looking at evidence outside the official court record.
- The U.S. Supreme Court denied Hamilton's initial petition for certiorari.
- Hamilton then filed a petition for a writ of coram nobis in the Alabama state courts, an extraordinary remedy to correct errors of fact.
- The Supreme Court of Alabama denied the coram nobis petition, holding that Hamilton had failed to show he was disadvantaged or prejudiced by the absence of counsel at his arraignment.
- The U.S. Supreme Court granted certiorari to review the Alabama Supreme Court's decision on the coram nobis petition.
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Issue:
Does denying an indigent defendant counsel at an arraignment in a capital case violate the Due Process Clause of the Fourteenth Amendment, even if the defendant pleads not guilty and cannot show specific prejudice resulted from the absence of counsel?
Opinions:
Majority - Mr. Justice Douglas
Yes. Denying an indigent defendant counsel at arraignment in a capital case violates the Due Process Clause of the Fourteenth Amendment because arraignment is a critical stage in the criminal process. The Court reasoned that under Alabama law, arraignment is not a mere formality but a critical stage where vital rights can be lost. Because defenses like insanity and pleas in abatement must be raised at arraignment or are waived, the absence of counsel at that stage can irretrievably prejudice the defendant. Citing Powell v. Alabama, the Court reiterated that an accused in a capital case requires the 'guiding hand of counsel at every step.' Therefore, when a defendant pleads to a capital charge without counsel, the court will not inquire whether prejudice resulted; the denial of counsel at a critical stage is itself a constitutional violation requiring reversal, as the degree of prejudice can never truly be known.
Analysis:
This case solidified the "critical stage" doctrine, clarifying that the Sixth Amendment right to counsel applies not just at trial but at any pre-trial phase where the accused's rights could be substantially affected. It established a rule of automatic reversal for the denial of counsel at a critical stage in a capital case, removing the defendant's burden to prove specific prejudice. This per se prejudice rule reinforced the fundamental importance of legal representation from the earliest stages of a prosecution and laid the groundwork for future expansions of the right to counsel in cases like Gideon v. Wainwright.
