Facts
- Johnson and a co-defendant, enlisted Marines on leave, were arrested in Charleston, South Carolina, for possessing and passing counterfeit $20 Federal Reserve notes.
- They were indicted in federal court and first notified of the indictment two days later.
- On the same day they were notified, they were arraigned, tried, convicted, and sentenced to four and one-half years’ imprisonment.
- They had counsel at earlier preliminary proceedings but had no counsel at trial.
- At arraignment, they pleaded not guilty, stated they had no lawyer, and indicated they were ready for trial.
- While incarcerated, Johnson sought habeas corpus, alleging denial of the Sixth Amendment right to counsel.
Issues
- Whether the Sixth Amendment guarantees a defendant in a federal criminal case the assistance of counsel as a prerequisite to the court’s authority to convict and sentence.
- Whether waiver of the right to counsel is valid only if made competently and intelligently, and whether the trial court must determine that waiver.
- Whether a conviction obtained without counsel and without a valid waiver is void and may be attacked collaterally by habeas corpus, including by evidence outside the trial record.
Decision
- The Supreme Court reversed the court of appeals and remanded.
- The Court held the Sixth Amendment entitles a person charged with crime in federal court to the assistance of counsel.
- The Court ruled that compliance with the right to counsel is an essential jurisdictional prerequisite to a federal court’s power to convict and sentence.
- The Court held the right may be waived only by a competent and intelligent waiver assessed under the defendant’s particular circumstances.
- The Court directed that the waiver question may be resolved in habeas proceedings using evidence beyond the trial record, and remanded for a determination whether Johnson validly waived counsel.
Legal Principles
- In federal criminal prosecutions, the Sixth Amendment right to counsel is a condition of the court’s authority to impose a valid conviction and sentence.
- Courts presume against waiver of fundamental constitutional rights and do not infer waiver from silence or mere acquiescence.
- A waiver of counsel is valid only if made competently and intelligently, considering the defendant’s background, experience, and conduct.
- Federal trial courts have a duty to protect the right to counsel and to determine whether an unrepresented defendant has validly waived counsel; making that determination part of the record is appropriate.
- Denial of counsel, or absence of a valid waiver, renders the conviction vulnerable to collateral attack in habeas corpus, and the habeas court may consider evidence outside the original trial record.
Conclusion
The Court held that a federal conviction obtained without counsel and without a competent and intelligent waiver is jurisdictionally defective, and that habeas corpus may be used to test the validity of any claimed waiver based on evidence beyond the trial record.