Gideon v. Wainwright
Gideon v. Wainwright is a landmark U.S. Supreme Court case decided in 1963, which established the right to counsel for indigent criminal defendants. The case arose when Clarence Earl Gideon, charged with breaking and entering, requested a court-appointed attorney, a request denied under Florida law that provided for such appointments only in capital cases. After representing himself and being convicted, Gideon filed a handwritten petition to the Supreme Court, arguing that his Sixth Amendment rights were violated. The Court, represented by attorney Abe Fortas, unanimously overturned the previous ruling in Betts v. Brady, which had limited the right to counsel based on special circumstances. This decision mandated that states are required to provide legal counsel to defendants who cannot afford an attorney in serious criminal cases. Gideon's case not only underscored the importance of legal representation but also set a precedent for subsequent cases related to defendants' rights, including Escobedo v. Illinois and Miranda v. Arizona. The outcome of Gideon v. Wainwright highlights the critical role that legal counsel plays in ensuring fair trials in the American justice system.
Gideon v. Wainwright
Date: March 18, 1963
Citation: 372 U.S. 335
Issue:Right to counsel
Significance: In this landmark case, the Supreme Court ruled that counsel must be provided for indigents accused of serious crimes.
Clarence Earl Gideon had convictions for petty crimes as a young man but no criminal convictions when he was arrested for breaking into a poolroom to steal coins and beverages. He requested an attorney be appointed for him, but the judge declined because Florida state law provided court-appointed attorneys only in capital cases. Although Gideon represented himself perhaps better than the average layperson, he was convicted and sentenced as a habitual criminal to five years in prison. While in prison, he filed an in forma pauperis (pauper’s) petition for a writ of habeas corpus.
In Betts v. Brady (1942), the Supreme Court required that states provide counsel only if special circumstances existed, but many states had developed legislation that provided court-appointed counsel for indigents. After 1951, the Court had consistently found “special circumstances” in every case involving states that failed to provide counsel for indigents, and many believed the Betts holding was ripe to be overturned. The Court appointed a well-known Washington, D.C., lawyer, Abe Fortas, who later became a Supreme Court justice, to represent Gideon. Fortas obtained a broad overturning of the Betts ruling. The Court unanimously reversed earlier decisions, including Betts v. Brady, that allowed states to fail to provide counsel to indigents accused of serious crimes by applying the Sixth Amendment to the states through incorporation.
When the case was returned to Florida, a newly appointed local attorney successfully attacked the prosecution’s case and demonstrated the wisdom of the Court’s requirement by showing that the most likely perpetrators of the crime were the very witnesses the prosecution had called against Gideon. Gideon laid the ground work for the far more controversial Escobedo v. Illinois (1964) and Miranda v. Arizona (1966), which involved police interrogations without the presence of legal counsel.
Bibliography
Bright, Stephen B., and Sia M. Sanneh. “Fifty Years of Defiance and Resistance after Gideon v. Wainwright.” Yale Law Journal 122.8 (2013): 2150–74. Academic Search Complete. Web. 7 Jan. 2016.
Houppert, Karen. Chasing Gideon: The Elusive Quest for Poor People’s Justice. New York: New, 2013. eBook Collection (EBSCOhost). Web. 7 Jan. 2016.
Israel, Jerold H. “Gideon v. Wainwright—From a 1963 Perspective.” Iowa Law Review 99.5 (2014): 2035–57. Academic Search Complete. Web. 7 Jan. 2016.
Jacob, Bruce R. “50 Years Later: Memories of Gideon v. Wainwright.” Florida Bar Journal 87.3 (2013): 10–17. Academic Search Complete. Web. 7 Jan. 2016.
Silva, Lahny R. “Right to Counsel and Plea Bargaining: Gideon’s Legacy Continues.” Iowa Law Review 99.5 (2014): 2219–44. Academic Search Complete. Web. 7 Jan. 2016.