Gideon v. Wainright

Gideon was charged with a felony in Florida state court. He appeared before the state Court, informing the Court he was indigent and requested that the Court appoint him an attorney. The Court declined to appoint Gideon an attorney, stating that under Florida law, the only time an indigent defendant is entitled to appointed counsel is when he is charged with a capital offense.

Facts of the case:

Clarence Earl Gideon was charged in Florida state court with felony breaking and entering. When he appeared in court without a lawyer, Gideon requested that the court appoint one for him. According to Florida state law, however, an attorney may only be appointed to an indigent defendant in capital cases, so the trial court did not appoint one. Gideon represented himself in trial. He was found guilty and sentenced to five years in prison. Gideon filed a habeas corpus petition in the Florida Supreme Court, arguing that the trial court’s decision violated his constitutional right to be represented by counsel. The Florida Supreme Court denied habeas corpus relief.

Rule:

The Sixth Amendment provides: In all criminal prosecutions, the accused shall enjoy the right to have the assistance of counsel for his defense. The court construes this to mean that in federal courts counsel must be provided for defendants unable to employ counsel unless the right is competently and intelligently waived.

Case Commentary:

The Court would build on this decision in cases such as Miranda v. Arizona, which held in part that defendants have a right to counsel even before a trial begins. Gideon also would lead to the implementation of a vast public defender system at the state level, which has spawned many other concerns such as inadequate funding and training, excessive workloads, and conflicts of interest. However, those flaws should not overshadow the triumph for the rights of criminal defendants marked by this decision. The ruling on appeal did not mean that Gideon was innocent of the charges but merely granted him the right to a new trial. However, Gideon’s lawyer thoroughly discredited the testimony of the prosecution’s only witness at the second trial, and he was acquitted after the jury had deliberated for only an hour.