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Case Brief Gideon v Wainwright
Course: Criminal Procedure (GOVT 302)
5 Documents
Students shared 5 documents in this course
University: Eastern Washington University
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Gideon v. Wainwright, 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963)
Parties
Gideon (Petitioner) vs. Wainwright (Respondent)
Procedure
Florida Supreme Court denied habeas corpus relief (petitioner lost)
United States Supreme Court ruled that right to legal counsel outlined in the 6th and 14th
Amendments was guaranteed (petitioner won)
Facts
Gideon was charged by a Florida state court with felony breaking and entering with the intent to
commit a misdemeanor. Gideon asked the court to provide a lawyer for him, but Florida state law
read that “the only time the Court can appoint Counsel to represent a Defendant is when that
person is charged with a capital offense”. The court did not appoint a lawyer and Gideon
defended himself. He was found guilty by jury and was sentenced five years of state prison.
Gideon filed a habeas corpus petition with the Florida Supreme Court on the grounds that the
state court’s refusal to appoint him Counsel was a violation of his constitutional rights. The
Supreme Court took his case on whether the right to Counsel under the Sixth Amendment was
guaranteed to defendants in state courts not being tried for a capital offense.
Issue
Is the trial court required under the Constitution (Sixth and Fourteenth Amendments) to appoint
Counsel if the defendant is unable to do so and has not committed a capital crime?
Is the absence of appointed Counsel a violation of the Constitution?
Rule
The United States Supreme Court ruled unanimously that legal counsel is a right of criminal
defendants in state and federal courts. “The Constitution makes no distinction between capital
and noncapital cases. The Fourteenth Amendment requires due process of law”. The previous
special circumstance rule is abandoned in noncapital cases that carry the possibility of a
substantial prison sentence.
Application
The United States Supreme Court used Powell v. Alabama as a precedent for their ruling in
Gideon v. Wainwright, saying that “the right to the aid of counsel is of this fundamental
character”. The Supreme Court agreed with Betts v. Brady that a fair trial is guaranteed in the
Fourteenth Amendment but disagreed with Betts v. Brady in that they now believe that the Sixth
Amendment’s right to counsel is a fundamental right.
Conclusion
The United States Supreme Court found in favor of the petitioner, Gideon, in that the Sixth and
Fourteenth Amendment guarantee a right to counsel of all criminal defendants regardless of
whether they are accused of a capital crime or special circumstances.
Discussion