White v. Maryland

Supreme Court of United States
373 U.S. 59 (1963)

ELI5:

Rule of Law:

The Sixth Amendment right to counsel applies to any pre-trial proceeding that qualifies as a 'critical stage' of a criminal prosecution. A preliminary hearing is a critical stage if the defendant enters a plea that is subsequently used as evidence against them at trial, regardless of the proceeding's label under state law.

Facts:

On May 27, 1960, Petitioner White was arrested.
White was brought before a magistrate for a preliminary hearing, which was eventually held on August 9, 1960.
At the August 9 preliminary hearing, White was not represented by counsel.
During this uncounseled preliminary hearing, White entered a plea of guilty.

Procedural Posture:

At Petitioner's trial in a Maryland state court, the guilty plea he made at the uncounseled preliminary hearing was introduced into evidence.
Petitioner was convicted and sentenced to death.
Petitioner appealed to the Maryland Court of Appeals, the state's highest court, arguing the admission of the uncounseled plea violated his constitutional rights.
The Maryland Court of Appeals affirmed the conviction, holding that a preliminary hearing was not a 'critical stage' requiring counsel under Maryland law.
The U.S. Supreme Court granted Petitioner's petition for a writ of certiorari to review the judgment of the Maryland Court of Appeals.

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Issue:

Does the Sixth Amendment right to counsel apply to a pre-trial preliminary hearing where a defendant, without an attorney, enters a guilty plea that is subsequently used as evidence against him at trial?

Opinions:

Majority - Per Curiam

Yes. The Sixth Amendment right to counsel applies to the preliminary hearing in this case because it was a 'critical stage' in the criminal proceeding. The court reasoned that regardless of the formal name or normal function of a 'preliminary hearing' under Maryland law, its actual function in this specific case made it critical. Because White entered a guilty plea without the advice of counsel, and that plea was later used against him at trial, his rights were impacted as significantly as if the plea had been entered at a formal arraignment. Citing Hamilton v. Alabama, the Court held that it does not need to determine whether the absence of counsel resulted in actual prejudice; the denial of counsel at a critical stage is itself a constitutional violation because 'Only the presence of counsel could have enabled this accused to know all the defenses available to him and to plead intelligently.'

Analysis:

This decision significantly broadens the application of the Sixth Amendment's right to counsel by defining 'critical stage' based on function rather than form. It establishes that the label a state gives to a pre-trial proceeding is irrelevant; what matters is the proceeding's potential to prejudice the defendant's rights. By extending the rule from Hamilton v. Alabama to a preliminary hearing where a plea was entered, the Court reinforced that the right to counsel attaches at any point where legal rights could be lost or defenses waived. This ruling also affirmed that the denial of counsel at a critical stage is a structural error not subject to a prejudice analysis, solidifying protections for defendants during the early, often confusing, stages of a criminal case.

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