Facts
- Clarence Earl Gideon was charged in Florida state court with breaking and entering a poolroom with intent to commit a misdemeanor, treated as a felony under Florida law.
- Gideon was indigent and requested that the trial court appoint counsel to represent him.
- The trial court denied the request because Florida law authorized appointment of counsel only in capital cases.
- Gideon represented himself at trial, including making an opening statement, cross-examining witnesses, presenting defense witnesses, and arguing to the jury.
- The jury convicted Gideon, and the court sentenced him to five years’ imprisonment.
- The Florida Supreme Court denied habeas relief without opinion.
- The U.S. Supreme Court granted certiorari to reconsider whether denial of counsel in state felony cases is constitutional, in light of prior precedent.
Issues
- Whether the Sixth Amendment right to the assistance of counsel is a fundamental right that applies to the states through the Fourteenth Amendment.
- Whether a state must appoint counsel for an indigent defendant charged with a noncapital felony.
- Whether the “special circumstances” approach permitting denial of counsel in some state felony cases should be retained.
Decision
- The Supreme Court unanimously reversed the Florida Supreme Court and remanded.
- The Court held that the Sixth Amendment right to counsel is fundamental and essential to a fair trial and is therefore binding on the states through the Fourteenth Amendment.
- The Court ruled that an indigent defendant’s felony conviction obtained without appointed counsel violates the Fourteenth Amendment.
- The Court overruled Betts v. Brady, which had allowed a case-by-case “special circumstances” inquiry for counsel in state felony prosecutions.
Legal Principles
- The Sixth Amendment guarantees an accused the right to the assistance of counsel in criminal prosecutions.
- Because the right to counsel is fundamental to a fair trial, the Fourteenth Amendment requires states to provide counsel to indigent defendants in felony prosecutions.
- Fairness in the adversarial system generally cannot be assured when a defendant faces prosecution without counsel due to poverty.
- A constitutional right that is “fundamental and essential to a fair trial” may not be conditioned on ad hoc determinations of “special circumstances.”
Conclusion
The Court held that states must appoint counsel for indigent defendants charged with felonies because the right to counsel is fundamental to a fair trial and applies to the states through the Fourteenth Amendment, making Gideon’s uncounseled conviction unconstitutional and requiring reversal and remand.