Gideon v. Wainwright Totally Explained

Everything about Gideon V Wainwright totally explained

Gideon v. Wainwright,, is a landmark case in United States Supreme Court history. In the case, the Supreme Court unanimously ruled that state courts are required under the Sixth Amendment of the Constitution to provide counsel in criminal cases for defendants unable to afford their own attorneys.

Background of the Case

The Supreme Court ruled in Powell v. Alabama,, the famous case of the Scottsboro Boys, that the right to counsel was implied in the Bill of Rights and was an essential freedom. In Betts v. Brady,, the Court modified this doctrine slightly, ruling that whether or not a lawyer was required would depend on the circumstances of each case. Specifically, the Court focused on a case-by-case determination of whether the lack of representation affected a denial of due process, rendering the trial unfair. Over the next twenty years, the Court heard several more cases, and in all of them ruled that in fact a lawyer was required. Due to the difficulty of proving the high standard of a due process error, nearly all such cases involved the death penalty. This view hadn't changed by the early 1960s.
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 after he'd been found with some wine in his possession and some change in his pockets. He appeared in court too poor to afford counsel, whereupon the following conversation took place:

The COURT: Mr. Gideon, I'm sorry, but I can't appoint Counsel to represent you in this case. Under the laws of 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'm sorry, but I'll have to deny your request to appoint Counsel to defend you in this case.
GIDEON: The United States Supreme Court says I'm 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 stationery, 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'd been denied counsel and, therefore, his Sixth Amendment rights, as applied to the states by the Fourteenth Amendment, had been violated.
   It is asserted by some that Gideon wrote his initial pleadings on toilet tissue when the prison guards refused to provide him with appropriate paper. The credibility of that assertion is enhanced by first-hand knowledge that, to this day, Florida Department of Corrections personnel are quick to identify and inhibit inmates who file writs (by various methods, including frequent transfers from camp to camp around the State).
   The court assigned him a prominent Washington, D.C. attorney, Abe Fortas (later a Supreme Court justice from 1965–1969) of the law firm Arnold & Porter.

Decision

The decision was announced on 18 March 1963; the opinion of the Court was delivered by Justice Hugo Black. The two concurrent opinions were written by Justices Clark and Harlan.
   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 meaning is 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.
   Justice Clark's concurrent opinion stated that the Constitution makes no distinction between capital and noncapital cases, so a defender needs to be provided in all cases. Justice Harlan's concurrent opinion stated that the mere existence of a serious criminal charge constituted in itself special circumstances requiring the services of counsel at trial.
   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.

Aftermath

Impact on courts

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. As a result, when Gideon came before the court they decided to reverse Betts and took upon a system of rules that didn't require a case-by-case analysis, but instead created the necessary procedure by its very nature. 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. 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.

Public defender system

Many changes have been made in the prosecution and legal representation of indigent defendants since the Gideon ruling was handed down in 1963. The decision in Gideon created and expanded public defenders. Immediately following the decision, Florida required that public defenders must work in all sixteen of the states circuit courts. The need for more public defenders also led to a need to ensure that the defenders are properly trained in legal defense to allow defendants to receive as fair of a case as possible. Several states and counties followed suit. Washington D.C., for instance, is one such city that has created a training program for their public defenders. Public defenders in District of Columbia must receive rigorous training before they're allowed to represent defendants, and they must continue their training in order to remain current and up-to-date. Another program in the Bronx in New York City requires public defenders to undergo training and provides defendants with “holistic training.”

Modern reform efforts

There are modern reform efforts that are aiming to expand the Gideon decision to include cases regarding property. In August 2006, the American Bar Association urged states to provide a lawyer for low-income people in categories of civil proceeding involving shelter, sustenance, safety, health, or childcare. The President of the American Bar Association stated that in regards to civil matters “poor litigants have basic human needs which deserve as much attention as the interest in liberty found to be the basic of criminal right to counsel in Gideon.” The decision of how this will proceed isn't yet finalized, but it's proposed that each state will have a say in which rights should be recognized by legislation.Further Information

Get more info on 'Gideon V Wainwright'.

External Link Exchanges

Do you know how hard it is to get a link from a large encyclopaedia? Well we're different and will prove it. To get a link from us just add the following HTML to your site on a relevant page:

<a href="http://gideon_v__wainwright.totallyexplained.com">Gideon v. Wainwright Totally Explained</a>

Then simply click through this link from your web page. Our crawlers will verify your link, extract the title of your web page and instantly add a link back to it. If you like you can remove the words Totally Explained and embed the link in article text.
As long as your link remains in place, we'll keep our link to you right here. Please play fair - our crawlers are watching. Your site must be closely related to this one's topic. Any kind of spamming, dubious practises or removing the link will result in your link from us being dropped and, potentially, your whole site being banned.