Gideon v. Wainwright, 372 U.S. 335 (1963), is a landmark case in United States Supreme Court history. In the case, the Supreme Court unanimously ruled that state courts are required by the Sixth and Fourteenth Amendments of the Constitution to provide lawyers in criminal cases for defendants unable to afford their own attorneys.
Facts: In 1961, Clarence Earl Gideon had been charged with burglary for breaking into a pool hall in Panama City, Florida and taking beer, wine, and change from the vending machines. He appeared in court too poor to afford counsel, whereupon the following conversation took place:
The COURT: Mr. Gideon, I am sorry, but I cannot appoint Counsel to represent you in this case. Under the laws of …show more content…
the State of Florida, the only time the Court can appoint Counsel to represent a Defendant is when that person is charged with a capital offense. I am sorry, but I will have to deny your request to appoint Counsel to defend you in this case.
GIDEON: The United States Supreme Court says I am entitled to be represented by Counsel.
Gideon had been forced therefore to act as his own counsel, and conducted a defense of himself in court, emphasizing his innocence in the case. Nevertheless, the jury returned a guilty verdict, sentencing him to serve five years in the state penitentiary. From his prison cell, at Florida State Prison, making use of the prison library, and writing in pencil on prison stationary, Gideon appealed to the U.S. Supreme Court in a suit against the Secretary to the Florida Department of Corrections, Louie L. Wainwright. His argument was that he had been denied counsel and therefore his Fourteenth Amendment rights had been violated without due process of law. The court assigned him a prominent Washington, D.C., attorney, Abe Fortas (later a Supreme Court justice from 19651969) of the law firm Arnold & Porter.
The decision was announced on 18 March 1963; the opinion of the Court was delivered by Justice Hugo Black.
In it, the court specifically praised its previous ruling in Powell v.
Alabama, and overruled Betts v. Brady, which allowed selective application of the Sixth Amendment right to counsel to the states, itself previously binding only in federal cases. Instead, the court held that the right to the assistance of counsel was a fundamental right, essential for a fair trial, thereby emphasizing the procedural safeguards which were needed for due process of law. In this sense, the court ruled specifically that no one, regardless of wealth, education or class, should be charged with a crime and then be forced to face his accusers in court without the guidance of counsel. All of the other justices concurred in the judgment.
The court remanded the case to the Supreme Court of Florida for "further action not inconsistent with this decision." Gideon was then retried: represented by W. Fred Turner, his appointed counsel in this second trial, he was acquitted.
Gideon v. Wainwright was one of a series of Supreme Court decisions which confirmed the right of defendants in criminal proceedings to counsel during trial, on appeal, and in the subsequent cases of Massiah v. United States 377 U.S. 201 (1964) and Miranda v. Arizona 384 U.S. 436 (1966), even during police interrogation.
Impact on
courts
At the time, this was one of select few that directly overturned a previous Supreme Court decision. Up until Gideon there had been fewer than 100 case decisions that had later been turned over by the Supreme Court in subsequent cases. The former arrangement of upholding the "fair trial" system, where the state was given a fair amount of latitude in criminal proceedings as long as there were no "shocking departures from fair procedure" was quickly being discarded in favor of a firm set of " procedural guarantees " stemming from previous constitutional amendments. [1] As a result, when Gideon came before the court they decided to reverse Betts and took upon a system of rules that did not require a case-by-case analysis, but instead created the necessary procedure by its very nature.[2] In this way, the case helped to refine stare decisis: when it should be upheld and what standard should case decisions be tested against precedent to achieve a legitimate practicability in the eyes of the Supreme Court and lower courts.[3] This confusion resulted in several new methods practiced by the Supreme Court when overturning a previous ruling to maintain the " impersonal qualities of the judicial process " and keep the sense that legal system is without feeling or prejudice and simply applies justice to those who come before it.[4]