Monday, June 13, 2005
Case Brief: Gideon v. Wainwright, 372 U.S. 335 (1963)
Here's another case brief that should make the lives of law school students and CJ students a whole lot easier. Please do not copy this verbatim. Instead, use it as reference for writing your own case brief. Sometimes the issues of older cases are hard to grasp compared to the varied legal issues surrounding the cases we work on today, which is the only reason I post my own briefs.
Name of the Case
Gideon v. Wainwright, 372 U.S. 335 (1963)
Facts of the Case
In a Florida State Court, Mr. Gideon was being charged with breaking into a poolroom with the intent to commit a misdemeanor, which is a felony in Florida. After making the court aware of the fact that he did not have any money, he requested for counsel to be appointed for him, but the court denied the request after citing the fact that counsel is only appointed for defendants in capital cases. Gideon conducted his own defense at the trial, and a jury convicted him and sent him to prison on a sentence of five years. He filed a habeas corpus petition, basing it on the grounds for his conviction, citing that he believed his rights, as guaranteed by the Constitution and the Bill of Rights were violated when the court denied him the assistance of counsel. The issue went to the Supreme Court, at which time they granted certiorari. The Court appointed counsel, and asked for the case of Betts v. Brady, 316 U.S. 455 to be reexamined in question of whether or not it should be reconsidered in order to grant a decision.
The issue in the case is whether or not the right to counsel is a guaranteed right to a defendant.
The court reversed and the cause was remanded.
Rationale for the Decision
The opinion of the Court was delivered by Justice Black. The case of Mr. Gideon was granted certiorari, and therefore the case of Betts v. Brady, 316 U.S. 455, would be the deciding factor. In the case of Betts, the defendant was indicted for robbing a bank, and subsequently requested the assistance of counsel to represent him in court due to the fact that he did not have any money. In the county where the offense occurred, it was not the practice of the judges to appoint counsel for defendants unless the charge was rape or murder, so the request was denied. After the trial, where the defendant pleaded not guilty and took the time to represent himself, he was found guilty at a bench trial and sentenced to eight years in prison. He filed for release via habeas corpus, citing that he had been denied the assistance of effective counsel as required under the Fourteenth Amendment. The Supreme Court denied the request, also, although after review in the matter of Gideon, the court decided to overrule the decision. The Court also review the language expressed by the Sixth Amendment, in which it is stated "… the accused shall enjoy the right … to have the Assistance of Counsel for his defence." The Court decided that the meaning of that would apply to Federal courts, and that counsel must be appointed unless "competently and intelligently waived." In the matter of States rights, the Court also accepts that the provisions outlined in the Bill of Rights provide for the assistance of counsel, and that the decision handed down in the matter of Betts was wrong, and that the Sixth Amendment allows for this guarantee, being that it is a fundamental right. The Court cites Grosjean v. American Press Co., 297 U.S. 233, 243-244 (1936), as well as Johnson v. Zerbst, 304 U.S. 458, 462 (1938), in which the fundamental right for defendants to be granted due process is made available through our legal system. The issue of indigence arises, and it is determined that anyone who is a defendant in a trial deserves the assistance of counsel, regardless of income range, quoting "The right of one charged with crime to counsel may not be deemed fundamental and essential to fair trials in some countries, but it is in ours." Justice Douglas and Justice Brewer join in the decision of the court.
Justice Clark and Justice Harlan concur in the decision of the court. Justice Clark notes that the Sixth Amendment requires the appointment of counsel in "all criminal prosecutions," and that the language of the Amendment is rather clear.
Holding of the Court
The right to counsel is a universal right, and one that is guaranteed under our Constitution, as well as the Bill of Rights. If a defendant is facing prosecution for a serious crime, or for a misdemeanor where a jail sentence could result, the defendant, regardless of income level, should be given the right to be assisted by counsel.