Powell v. Alabama

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Following is the case brief for Powell v. Alabama, United States Supreme Court, (1932)

Case summary for Powell v. Alabama:

  • Powell and eight other African American men were convicted of raping two white women on a train.
  • The trial judge did not assign specific counsel to each of the men and instead listed “all members of the bar” as counsel.
  • On the morning of the scheduled trial, two attorneys volunteered and proceeded to wrap up the case in one day. Powell and the others appealed, claiming their 14th Amendment Due Process rights were violated.
  • The Court held that in a capital case, the criminal defendant has a right to notice and a hearing. The right to a hearing also requires the right to counsel. Here, the proper amount of time required to prepare a defense was not allotted in violation of the 14th Amendment’s Due Process Clause.

Powell v. Alabama Case Brief

Statement of the facts:

Powell was one of nine illiterate African American men convicted of raping two white women. Under the over sight of the trial judge, none of the men were afforded an attorney or given the opportunity to contact their families or secure representation.  The trial judge did assign “all members of the bar” to counsel the nine men at their arraignment. On the morning of trial two attorneys volunteered to represent the men. Each separate trial was decided in one day and the three juries from the three separated trials convicted all of the men, sentencing them to death. The men’s motions for a new trial were all overruled.

Procedural History:

On appeal, the state supreme court affirmed the lower court’s judgment. In response Powell, along with the other men, filed a writ of certiorari with the United States Supreme Court. The Court granter certiorari.

Rule of Law or Legal Principle Applied:

Under the concept of Due Process, criminal defendants possess the right to counsel at trial and in the time leading up to trial.

Issue and Holding:

Whether the Due Process rights of the accused are violated in a capital case where the judge fails to appoint a defense attorney until the morning of trial? Yes.

Judgment:

The Supreme Court reversed and remanded the case back to the trial court.

Reasoning:

When a defendant is unable to either employ his own counsel or adequately represent himself, in a capital case, the trial judge must appoint counsel. This is necessary regardless of whether or not the defendant requests counsel. The 14th Amendment’s Due Process Clause provides a criminal defendant with the right to notice and a hearing.

The Court held that the right to a hearing in capital cases, includes the right to counsel. This is because generally most people are not familiar with legal proceedings and not adequately prepared to defend themselves as a result. Under the right to counsel an individual should be able to consult with their attorney before trial to prepare a defense.

Here, Powell’s trial judge violated Powell’s Due Process rights when he failed to provide all nine men with the opportunity to obtain counsel.  When taking into consideration their age, inability to read, ignorance of the law and severity of the charges, it is apparent the nine men could not have effectively defended themselves.

In addition, assigning “all members of the bar” at arraignment the judge also failed to assign proper counsel since no specific attorney was assigned to the case until the day of trial. As a result, the Court concluded that the proper amount of time required to prepare a defense was not allotted in violation of the 14th Amendment.

Concurring or Dissenting opinion:

Dissenting (Butler):

Preparation on the same morning of trial is adequate preparation and does not violate Powell’s Due Process rights under the 14th Amendment. The attorneys who volunteered to defend the case never requested a postponement and failed to establish that they were not prepared on the day of trial.

In regards to not assigning counsel, the Court oversteps its authority when it holds the failure of the trial judge to appoint the nine men with counsel violates the 14th Amendment.

Significance:

This case shaped the importance of Due Process and what those rights entail, specifically the right to an attorney. The right to an attorney includes adequate preparation to construct a proper defense for a criminal defendant charges with a capital offense.

Student Resources:

https://www.law.cornell.edu/supremecourt/text/287/45
https://supreme.justia.com/cases/federal/us/287/45/case.html