Following is the case brief of Gideon v. Wainwright, The Supreme Court of the United States, (1963)
Case Summary of Gideon v. Wainwright:
- Gideon was charged with a felony in a state that only required the court to appoint counsel in capital cases.
- After denial of his request to have court-appointed counsel, Gideon represented himself and was convicted.
- Gideon then appealed his conviction to the United States Supreme Court, who granted certiorari.
- The Supreme Court held that the Sixth Amendment right to trial is incorporated to the states through the 14th Amendment.
Statement of the Facts:
Gideon had been charged with a felony under Florida state law. His request for the court to appoint him a lawyer was denied. Gideon ended up representing himself at trial because state law did not require the court to appoint counsel in non-capital cases. Gideon was ultimately convicted by a jury. He then petitioned to the United States Supreme Court. The Supreme Court granted certiorari.
Gideon was convicted of a state felony after being denied his request to the court to appoint counsel. Gideon then petitioned to the Supreme Court of the United States and the Court granted certiorari.
Issue and Holding:
Do the states have the Sixth Amendment right to counsel through the 14th Amendment? Yes.
The decision of the Florida court was reversed.
Rule of Law or Legal Principle Applied:
The Sixth Amendment right to counsel is incorporated to the states through the 14th Amendment.
The Bill of Rights that are “fundament and essential” to a fair trial are incorporated to the states through the 14th Amendment. This encompasses the Sixth Amendment right to counsel. In Betts v. Brady, 316 U.S. 455 (1963), the court assumed the state’s refusal to appoint counsel was not a violation of the fundamental principals of fairness and no due process violation occurred.
This Court held that the Betts decision should be overruled, not just because it is not good law, but because it is not consistent with then-existing precedent. In Powell v. Alabama, 287 U.S. 45 (1932), the court stated that the Sixth Amendment right to counsel is a fundamental right.
As a result, the Court must acknowledge this Sixth Amendment right as fundamental to a fair trial as it requires the states to provide a defendant with a competent advocate who is present at trial.
The majority properly overruled Betts, but the Court improperly held the Betts decision was inconsistent with then existing precedence.
This landmark case identified the Sixth Amendment right to counsel as a fundamental right that is incorporated to the states through the 14th Amendment. Prior to this decision, many states only required counsel to be appointed in capital cases.