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Saturday, July 5, 2014

Gideon v. Wainwright Case Brief

Gideon v Wainwright Case Brief
A burglary occurred at the Bay Harbor Pool Room early in the morning on June 3, 1961. There were no eyewitnesses who saw the face of the burglar. However, later on that same day, a witness made a report that he had seen the defendant, one Clarence Gideon, lurking around the said poolroom at around 5:30 that same morning. He was said to have on his person money and a wine bottle. By virtue of this statement, Gideon was arrested and charged. On his appearance in court, he was without counsel due to the fact that he was poor and unable to afford one. He requested to be afforded counsel but was denied. According to the records, the court denied him counsel because under Florida laws, counsel would only be provided to an indigent defendant only if he had committed a capital offense. As Gideon was charged with mere breaking and entering with intent to commit petty larceny, he did not qualify. Because of this and despite his complaints, Gideon was forced to represent himself during his trial. He was adjudged guilty of the crimes he was accused of.  He was sentenced to 5 years of imprisonment by the State Supreme Court.

However, during his stay in prison, Gideon was able to send out a letter of appeal to the United States Supreme Court, relating how he was denied counsel. He contended that his Sixth Amendment rights had been violated. He likewise filed a suit against the then Secretary of the Florida Department of Corrections for this event.

Procedural History
The case was filed at a Florida State Court and was decided upon by the United States of America Supreme Court.

The issue is whether or not the denial of counsel to an indigent client in a criminal trial is violative of the Fourteenth Amendment.

Due process is a right guaranteed to the accused by the Sixth Amendment.

Due process is essential if any accused is to have a fair trial. This concept is supported by the Sixth Amendment which provides that in all criminal trials, the accused shall have the assistance of counsel for his defense. The Court emphasized that in application, this right is and should be available to everyone. The right to counsel may only be dispensed with if it is competently as well as intelligently waived by the accused himself.

In relation to the case of Gideon, the Court deemed that State courts are no exception to this rule, no matter what policies they may happen to have in place. Although States are not obliged by the law in concrete phraseology, such a concept is regarded as so intrinsic, so fundamental, and so basic that it is something automatically applicable to anyone and everyone without any exceptions. It should not have been denied from Gideon no matter the status of his case.

In applying the aforementioned rule in this case, the Court, in effect, overthrew the prevailing doctrine that was established in the case of Betts v Brady which had provided that a court appointed attorney was not essential to criminal proceedings except in extreme, complicated, or unusual circumstances. It set a new standard and established that indeed, Gideon was wrongfully denied of his rights and he was unfairly adjudged.


It was established in this case that the right of an indigent defendant to have the assistance of counsel in a criminal case is indispensable for a fair trial to commence. A trial and conviction without the assistance of counsel, as in this case, is violative of the Fourteenth Amendment.

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