Gideon v. Wainwright

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 The United States Supreme Court’s decision was unanimous in that the right to counsel is guaranteed in the Constitution. Previously, the right to counsel was only given to criminal defendants charged with capital offenses, not those with felony or misdemeanor charges. Through Gideon v. Wainwright, all criminal defendants across all fifty states are now guaranteed the right to counsel during trial. The right to “have the Assistance of Counsel for his defence” is guaranteed in the Sixth Amendment of the United States Constitution. The Fourteenth Amendment also reads that no state should be able to “deprive any person of life, liberty, or property, without due process of the law; nor deny to any person within its jurisdiction the equal protection of the laws”. The Supreme Court and other courts were able to look past this for a long time because they had a “special circumstances rule” that was used when trying people for capital crimes and they thought that was enough. By the time of Gideon’s original case, the special circumstance rule had been abandoned in capital crime trials, meaning that anyone charged with a capital crime was provided counsel if they were unable to do so themselves, however there was still a special circumstance rule for noncapital cases. The ruling of this case showed that the special circumstance rule concerning noncapital cases should be abandoned in noncapital crimes as well, at least in those that carry the possibility of a prison sentence. It took until the Gideon case for the Supreme Court to recognize this because they had previously ruled in Powell and Betts and thought that the wording of their rulings in those cases was enough. The Constitution does not make a distinction between capital and noncapital cases in its wording of the Sixth Amendment, but somewhere in time someone decided that the capital cases are the ones that need counsel, where other criminal defendants do not have as much on the line. The benefits to the right of counsel are many, including that every criminal defendant has competent, trained legal assistance to help with their case, and it is not the defendant defending themselves with no knowledge of criminal law. Having the right to counsel for defendants ensures that there is a more even playing field in the courtroom against the prosecution, and it ensures that one’s case will not fall through the cracks and take longer than it should (the right to a speedy trial). It also ensures that the jury is not swayed by outside factors like the economics of the defendant, because they are not made aware that the defendant had counsel appointed for them, they just see counsel in the court room. This also ensures that the defendant understands the legal terminology relevant to their case, as well as their sentencing or plea deal that they accept. This is good for the court system as well, because then the defendant cannot come back to the courts or go to a higher court after their trial and say they only took a deal because they did not understand what was going on, or that their lack of knowledge influenced their case. This also makes a big difference socioeconomically, because statistically it is inner-city areas that have the most crime, and inner-city areas are often more diverse and contain more minorities than suburbs or rural areas, where crime is lower. Having counsel appointed to those that cannot afford it in high-crime areas helps to ensure that there is some form of racial equality in the courts and those that cannot afford counsel are not left to fend for themselves simply because they are poor.