Gideon v. Wainwright

Gideon Wainwright (372 U.S. 335) was a landmark U.S. Supreme Court case decided in 1963 involving the right to counsel protected by the Sixth Amendment of United States Constitution. The Supreme Court ruled that if a felony defendant is too poor to obtain an attorney to represent him in the trial, the court should appoint an attorney for the defendant.

Factual background

In 1961, Clarence Earl Gideon was charged with burglary but was too poor to hire an attorney. He represented himself in the trial, was convicted and sentenced to five years imprisonment. He appealed and claimed that he did not receive a fair trial because of the lack of counsel.

Precedents

Prior to this case, there had been several Sixth Amendment right to counsel decisions. In Powell v. Alabama, decided in 1932, the majority opinion by Justice George Sutherland established the guaranteed counsel in capital cases. In 1938 the court extended the guaranteed counsel to federal felony cases in the case Johnson v. Zerbst. However, in the 1942 case Betts v. Brady through the opinion penned by Justice Owen Roberts the court denied the right to court-appointed counsel to non-capital state criminal defendants.

Decision

The court decided unanimously that Gideon should have the right to a court-appointed attorney. Betts v. Brady was overruled. The opinion was penned 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.

Sources

• Oyez.org
• Full opinion of the court
• Champion Magazine