Gideon v. Wainwright: Difference between revisions
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== | ''' ''Gideon v. Wainwright'' ''', 372 U.S. 335 (1963), was a landmark [[Supreme Court of the United States]] case regarding the right to counsel protected by the Sixth Amendment of the [[United States Constitution]]. The Court ruled, 9-0, that if a [[felony]] defendant is too poor to hire an [[attorney]] to represent him at trial, the trial court must appoint an attorney for him. | ||
In Florida in 1961, [[Clarence Earl Gideon]] was charged with burglary but was too poor to hire an attorney. He asked the court to appoint counsel to represent him at trial, but the court denied that request based on existing law, which did not reqire counsel to be appointed in non-capital cases. So Gideon represented himself at the jury trial, was convicted, and was sentenced to five years of [[imprisonment]]. He filed for a writ of ''habeas corpus'', against Wainwright, the corrections director, and claimed that he had not received a fair trial because of the lack of counsel. The Supreme Court of Florida denied his petition (135 So.2d 746), but Gideon took that denial up to the U.S. Supreme Court. | |||
==Facts of the case== | |||
In Florida in 1961, [[Clarence Earl Gideon]] was charged with [[burglary]] but was too poor to hire an attorney. He asked the court to appoint counsel to represent him at trial, but the court denied that request based on existing law, which did not reqire counsel to be appointed in non-capital cases. So Gideon represented himself at the jury trial, was convicted, and was sentenced to five years of [[imprisonment]]. He filed for a writ of ''[[habeas corpus]]'', against Wainwright, the corrections director, and claimed that he had not received a fair trial because of the lack of counsel. The Supreme Court of [[Florida (U.S. state)|Florida]] denied his petition (135 So.2d 746), but Gideon took that denial up to the U.S. Supreme Court. | |||
==Precedents== | ==Precedents== | ||
Prior to this case, there had been several Sixth Amendment | Prior to this case, there had been several [[United States Constitution|Sixth Amendment]] right-to-counsel decisions: In ''Powell v. Alabama'', 287 U.S. 45 (1932), the majority opinion by Justice [[George Sutherland]] established the right to counsel in capital (that is, [[capital punishment|death-penalty]]) cases. In 1938 the court extended the guarantee of counsel to defendants in federal felony cases in ''Johnson v. Zerbst'', 304 U.S. 458 (1938). In the 1942 decision in ''Betts v. Brady'', 316 U.S. 455 (1942), however, in an opinion penned by Justice [[Owen Roberts]], the court had not broadened the right to court-appointed counsel to cover criminal defendants in non-capital cases in state courts. | ||
==Decision== | ==Decision== | ||
The court decided unanimously that Gideon had a right to a court-appointed attorney. ''Betts v. Brady'' was overruled. The opinion was written by Justice [[Hugo Black]], who was also the author of ''Johnson v. Zerbst'' and a dissenter in ''Betts v. Brady''. Justice [[William Douglas]] and [[John Marshall Harlan II]] wrote separate concurring opinions. | The court decided unanimously that Gideon had a right to a court-appointed attorney. ''Betts v. Brady'' was overruled. The opinion was written by Justice [[Hugo Black]], who was also the author of ''Johnson v. Zerbst'' and a dissenter in ''Betts v. Brady''. Justice [[William Douglas]] and [[John Marshall Harlan II]] wrote separate concurring opinions. | ||
==Application to misdemeanor defendants== | |||
While ''Gideon'' extended the right-to-counsel to felony defendants where the death penalty was not a possible sentence, it did not address the issue of indigent defendants accused of misdemeanors instead of felonies. In ''Argersinger v. Hamlin'', 407 U.S. 25 (1972), with the majority opinion authored by [[William Douglas]], the court broadened ''Gideon'''s rationale to cover misdemeanor defendants where any imprisonment was a possible sentence, establishing that those defendants also have the right to court-appointed counsel if unable to pay for private attorneys. So now if an indigent defendant charged with any crime for which the law allows the court to impose a sentence of even one day in jail -- even a traffic ticket -- asks for counsel to be appointed, either the court must appoint counsel or (if the defendant is convicted or pleads guilty) the sentence imposed cannot include any "jail time." | |||
==Media== | ==Media== | ||
The case was the subject of the 1980 made-for-television movie ''Gideon's Trumpet'' | The case was the subject of the 1980 made-for-television movie ''Gideon's Trumpet'' starring [[Henry Fonda]] as Clarence Gideon.[[Category:Suggestion Bot Tag]] | ||
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Latest revision as of 06:00, 22 August 2024
Gideon v. Wainwright , 372 U.S. 335 (1963), was a landmark Supreme Court of the United States case regarding the right to counsel protected by the Sixth Amendment of the United States Constitution. The Court ruled, 9-0, that if a felony defendant is too poor to hire an attorney to represent him at trial, the trial court must appoint an attorney for him.
Facts of the case
In Florida in 1961, Clarence Earl Gideon was charged with burglary but was too poor to hire an attorney. He asked the court to appoint counsel to represent him at trial, but the court denied that request based on existing law, which did not reqire counsel to be appointed in non-capital cases. So Gideon represented himself at the jury trial, was convicted, and was sentenced to five years of imprisonment. He filed for a writ of habeas corpus, against Wainwright, the corrections director, and claimed that he had not received a fair trial because of the lack of counsel. The Supreme Court of Florida denied his petition (135 So.2d 746), but Gideon took that denial up to the U.S. Supreme Court.
Precedents
Prior to this case, there had been several Sixth Amendment right-to-counsel decisions: In Powell v. Alabama, 287 U.S. 45 (1932), the majority opinion by Justice George Sutherland established the right to counsel in capital (that is, death-penalty) cases. In 1938 the court extended the guarantee of counsel to defendants in federal felony cases in Johnson v. Zerbst, 304 U.S. 458 (1938). In the 1942 decision in Betts v. Brady, 316 U.S. 455 (1942), however, in an opinion penned by Justice Owen Roberts, the court had not broadened the right to court-appointed counsel to cover criminal defendants in non-capital cases in state courts.
Decision
The court decided unanimously that Gideon had a right to a court-appointed attorney. Betts v. Brady was overruled. The opinion was written by Justice Hugo Black, who was also the author of Johnson v. Zerbst and a dissenter in Betts v. Brady. Justice William Douglas and John Marshall Harlan II wrote separate concurring opinions.
Application to misdemeanor defendants
While Gideon extended the right-to-counsel to felony defendants where the death penalty was not a possible sentence, it did not address the issue of indigent defendants accused of misdemeanors instead of felonies. In Argersinger v. Hamlin, 407 U.S. 25 (1972), with the majority opinion authored by William Douglas, the court broadened Gideon's rationale to cover misdemeanor defendants where any imprisonment was a possible sentence, establishing that those defendants also have the right to court-appointed counsel if unable to pay for private attorneys. So now if an indigent defendant charged with any crime for which the law allows the court to impose a sentence of even one day in jail -- even a traffic ticket -- asks for counsel to be appointed, either the court must appoint counsel or (if the defendant is convicted or pleads guilty) the sentence imposed cannot include any "jail time."
Media
The case was the subject of the 1980 made-for-television movie Gideon's Trumpet starring Henry Fonda as Clarence Gideon.