United States v. Wade
United States v. Wade is a landmark Supreme Court case that addresses the rights of defendants during police lineups, particularly the right to legal counsel. The case emerged from a bank robbery incident involving the defendant, Wade, who participated in a lineup without an attorney present. The Supreme Court, in a closely divided 5-4 decision, ruled that the lineup process violated the Fifth Amendment rights against self-incrimination. Justice William J. Brennan, Jr. authored the majority opinion, emphasizing that this stage of proceedings is critical, thereby necessitating the appointment of counsel for defendants unable to afford one. This decision marked a significant expansion of the right to counsel, building upon prior rulings such as Miranda v. Arizona. The dissenting opinions raised concerns about the classification of lineups as critical stages and self-incrimination, highlighting the ongoing debate about procedural rights in the justice system. Overall, United States v. Wade underscores the complexities of due process and the evolving interpretation of legal rights for defendants in criminal proceedings.
United States v. Wade
Date: June 12, 1967
Citation: 388 U.S. 218
Issue: Right to counsel
Significance: The Supreme Court’s decision further expanded the defendant’s right to counsel beyond its 1966 ruling.
Wade, a defendant in a bank robbery case, was placed in a police lineup without having an attorney present. In the lineup, he and the others were required to wear a mask and say, “Put the money in the bag.” By a 5-4 vote, the Supreme Court held that this setting and the required statement were self-incriminating and in violation of the Fifth Amendment. In his opinion for the Court, Justice William J. Brennan, Jr., overturned Wade’s conviction and stated that the lineup was a critical stage in the proceedings, mandating the appointment of counsel for indigents. The Court’s decision greatly expanded the right to counsel that had already been increased by Miranda v. Arizona (1966). Chief Justice Earl Warren and Justice William O. Douglas joined in an opinion written by Justice Abe Fortas overturning the conviction but rejecting the Court’s finding that the lineup procedures were self-incriminating. Justices John M. Harlan II and Potter Stewart joined in a dissent by Justice Byron R. White upholding the conviction and rejecting the Court’s view that the lineup is a critical stage in the proceedings. Justice Hugo L. Black upheld the conviction but rejected the Court’s holding that the lineup constituted self-incrimination.
