Clarence Earl Gideon was an unlikely hero. He was a man with an eighth-grade education who ran away from home when he was in middle school. He spent much of his early adult life as a drifter, spending time in and out of prisons for nonviolent crimes. Gideon was charged with breaking and entering with the intent to commit a misdemeanor, which is a felony under Florida law. At trial, Gideon appeared in court without an attorney. In open court, he asked the judge to appoint counsel for him because he could not afford an attorney. The trial judge denied Gideon’s request because Florida law only permitted appointment of counsel for poor defendants charged with capital offenses. At trial, Gideon represented himself – he made an opening statement to the jury, cross-examined the prosecution’s witnesses, presented witnesses in his own defense, declined to testify himself, and made arguments emphasizing his innocence. Despite his efforts, the jury found Gideon guilty and he was sentenced to five years imprisonment.
While serving his sentence, Gideon filed a petition for habeas corpus (a writ requiring a person under arrest to be brought before a judge or into court, especially to secure the person’s release unless lawful grounds are shown for their detention.) attacking his conviction and sentence on the ground that the trial court’s refusal to appoint counsel denied his constitutional rights and rights guaranteed him under the Bill of Rights. Gideon sought relief from his conviction by filing a petition for writ of habeas corpus in the Florida Supreme Court. In his petition, Gideon challenged his conviction and sentence on the ground that the trial judge’s refusal to appoint counsel violated Gideon’s constitutional rights. The Florida Supreme Court denied Gideon’s petition. Gideon next filed a handwritten petition in the Supreme Court of the United States. The Court agreed to hear the case to resolve the question of whether the right to counsel guaranteed under the Sixth Amendment of the Constitution applies to defendants in state court.
Procedure: Lower Courts: Bay County Circuit Court, Fourteenth Judicial Circuit of Florida Lower Court Ruling: The trial judge denied Gideon’s request for a court-appointed attorney because, under Florida law, counsel could only be appointed for a poor defendant charged with a capital offense. The Florida Supreme Court agreed with the trial court and denied all relief.
Issue: A prior decision of the Court’s, Betts v. Brady, 316 U.S. 455 (1942), held that the refusal to appoint counsel for an indigent defendant charged with a felony in state court did not necessarily violate the Due Process Clause of the Fourteenth Amendment. The Court granted Gideon’s petition for a writ of certiorari – that is, agreed to hear Gideon’s case and review the decision of the lower court – in order to determine whether Betts should be reconsidered.
Ruling: Reversed and remanded. In its opinion, the Court unanimously overruled Betts v. Brady. Argued: January 15, 1963 Decided: March 18, 1963 Unanimous Decision: Justice Black (who dissented in Betts) wrote the opinion of the court. Justices Douglas, Clark, and Harlan each wrote concurring opinions.
Reasoning: The Court held that the Sixth Amendment’s guarantee of counsel is a fundamental right essential to a fair trial and, as such, applies the states through the Due Process Clause of the Fourteenth Amendment. In overturning Betts, Justice Black stated that “reason and reflection require us to recognize that in our adversary system of criminal justice, any person hauled into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided for him.” He further wrote that the “noble ideal” of “fair trials before impartial tribunals in which ever defendant stands equal before the law . . . cannot be realized if the poor man charged with crime has to face his accusers without a lawyer to assist him.”
Does the Sixth Amendment’s right to counsel in criminal cases extend to felony defendants in state courts? The Sixth Amendment’s guarantee of a right to assistance of counsel applies to criminal defendants in state court by way of the Fourteenth Amendment.
In a unanimous opinion authored by Justice Hugo L. Black, the Court held that it was consistent with the Constitution to require state courts to appoint attorneys for defendants who could not afford to retain counsel on their own. The Court reasoned that the Sixth Amendment’s guarantee of counsel is a fundamental and essential right made obligatory upon the states by the Fourteenth Amendment. The Sixth Amendment guarantees the accused the right to the assistance of counsel in all criminal prosecutions and requires courts to provide counsel for defendants unable to hire counsel unless the right was competently and intelligently waived. Justice Douglas, while joining the Court’s opinion, elaborated, in a separate opinion, the relation between the Bill of Rights and the first section of the Fourteenth Amendment. Justices Clark and Harlan concurred in separate decisions.
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