Gideon v Wainwright Case Brief
Facts
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.
Issue
The issue is whether
or not the denial of counsel to an indigent client in a criminal trial is
violative of the Fourteenth Amendment.
Rule/s
Due process is a
right guaranteed to the accused by the Sixth Amendment.
Application
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.
Conclusion
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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