Gideon v. Wainwright

Gideon v. Wainwright 1963

Gideon v. Wainwright is one of three landmark Supreme court cases in which the Supreme Court transformed the criminal justice system. The Supreme Court ruled that a poor person charged with a felony had the right to a state-appointed lawyer.

See also:Escobedo v. Illinois(1964), Miranda v. Arizona (1966).

U.S. Supreme Court

GIDEON v. WAINWRIGHT, 372 U.S. 335 (1963)*

GIDEON v. WAINWRIGHT, CORRECTIONS DIRECTOR.
CERTIORARI TO THE SUPREME COURT OF FLORIDA.
No. 155.
Argued January 15, 1963.
Decided March 18, 1963.

Charged in a Florida State Court with a noncapital felony, petitioner appeared without funds and without counsel and asked the Court to appoint counsel for him; but this was denied on the ground that the state law permitted appointment of counsel for indigent defendants in capital cases only. Petitioner conducted his own defense about as well as could be expected of a layman; but he was convicted and sentenced to imprisonment. Subsequently, he applied to the State Supreme Court for a writ of habeas corpus, on the ground that his conviction violated his rights under the Federal Constitution. The State Supreme Court denied all relief.

Held:

The right of an indigent defendant in a criminal trial to have the assistance of counsel is a fundamental right essential to a fair trial, and petitioner's trial and conviction without the assistance of counsel violated the Fourteenth Amendment. Betts v. Brady, 316 U.S. 455*, overruled. Pp. 336-345.

Reversed and cause remanded.

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See Also: Landmark Case, Civil Rights Rulings (Circa 1960's)
* Click here to understand what those numbers mean

Gideon v. Wainwright (1963) was a landmark decision regarding due process. In a Florida state court, Gideon was charged for breaking and entering, which was a felony. Gideon lacked funds, therefore was unable to hire a lawyer to prepare his defense. The court refused when he requested that an attorney be appointed for him. The state reasoned that it was only obligated to appoint counsel to indigent defendants in capital cases. Hence, Gideon was forced to defend himself in the trial, which caused him to be convicted by a jury. He was sentenced to five years in a state prison.

This matter was brought to the Supreme Court, who asked the question: Did the state court's failure to appoint counsel for Gideon violate his right to a fair trial and due process of law as protected by the Sixth and Fourteenth Amendments? The Court answered that yes, the state court's failure to appoint counsel for Gideon did violate his rights.

This was an unanimous opinion, where the Court held that Gideon had a right to be represented by a court-appointed attorney. The Supreme Court stated that states are required to provide counsel to defendants who cannot afford it. The Supreme Court reasoned that the Fourteenth Amendment due process clause is applicable to the states as well as federal proceedings. They also found that the Sixth Amendment's guarantee of counsel was a fundamental right and was essential to a fair trial. It was argued that a fair trial for a poor defendant couldn't be guaranteed without the assistance of counsel. "The right of one charged with crime to counsel may not be deemed fundamental and essential to fair trials in some countries, but it is in ours."

This landmark decision had many consequences. First of all, it required that states be required to provide counsel to defendants who cannot afford it in noncapitals as well as in capital cases. In other words, it assured that every body would have a chance to have a defense, hence making trials in the United States much more fair and impartial. It also overruled the Betts v. Brady (1942) decision.

If interested, then you may enjoy the 1980 movie Gideon's Trumpet starring Henry Fonda as Clarence Earl Gideon. Thanks Quizro!

Sources:http://oyez.nwu.edu/cases/cases.cgi and notes from Government class.