Gideon V. Wainwright Summary

Case Citation: Gideon v. Wainwright, 372 U.S. 335 (1963).

Parties: Clarence Earl Gideon, Petitioner / Respondent Louie L. Wainwright, Division of Corrections
Facts: Clarence Earl Gideon was charged in Florida state court with a felony: for illegally entering a pool hall with the intention of committing a misdemeanor. When Gideon arrived in court he requested an attorney as he could not afford one at that time. However, in accordance with Florida state law at the time the court told Mr. Gideon that they were unable to appoint an attorney for him as the case was not for a capital offense. Mr. Gideon was found guilty at trial and was sent to five years in prison. Gideon petitioned the Florida State Supreme court habeas corpus in which he argued that he Bay County court's decision violated his constitutional right to be represented a lawyer at trial. The Florida State Supreme Court denied relief. Reasoning that the Supreme Court of the United States created

controversy in that area when it granted a writ of of certiorari in the Betts v. Brady to decide a defendant’s constitutional right to counsel in state court.
Procedural History: Bay County, Florida State Trial Court 14th circuit: convicted; Appellate Court; Florida State Supreme Court: affirmed; US Supreme Court: reversed and cause remanded
Issues:

Issue 1: Whether the Sixth Amendment's right to counsel in felonious cases encompass felony defendants in state courts as well?

Holdings:

Issue 1: Yes. The right of a defendant who cannot provide their own counsel in a criminal trial to have the assistance of such is an essential right vital to a fair trial, and Mr. Gideon’s trial and conviction devoid of the assistance of counsel violated the Fourteenth Amendment. Betts v. Brady, 316 U. S. 455, overruled. Pp. 372 U. S. 336-345.

Reasoning: Appellants advanced the following theories in support of their position:

Issue 1: The right of an indigent defendant to appointed counsel is a fundamental right, crucial to a fair trial. Failure to make an attorney available to an indigent defendant is a violation of the Fourteenth Amendment of the United States

Constitution.

Decision: The Supreme Court held that the writers of the Constitution assessed extraordinary value on the right of the accused to be able to be defended appropriately, and the state as well as federal courts must respect that right. The Court held that it was in accordance with the Constitution to necessitate state courts to appoint attorneys for defendants who otherwise would not be able to afford to retain counsel otherwise.
Comment: The Supreme Court, when reasoning its conclusion that the right to counsel is an important right enforced upon the states in accordance with to the Fourteenth Amendment of the Constitution, engages in an analysis of its prior judgements holding that other provisions of the Bill of Rights are fundamental rights made mandatory to the States. The Supreme Court accepts the Betts v. Brady theory that a provision of the Bill of Rights which is fundamental and essential to an unbiased trial is made mandatory on the states by the Fourteenth Amendment of the Constitution. The Supreme Court separates from the Betts case in that they believe the right to support from competent counsel is a fundamental right. The Supreme Court found that the Betts Court’s supposition that aid of counsel is not an essential right is an unexpected break from its own well-considered precedent. The Supreme Court additionally details that the right to be heard at trial would be, in most cases, ineffective lacking the support of competent counsel that is accustomed with the procedures of court, the rules of evidence and the common processes of the court system. Deprivation of the assistance of counsel Justice Douglas wrote in his concurrence: “though he be not guilty, he faces the danger of conviction because he does not know how to establish his innocence.”