Clarence Earl Gideon was a man with an eighth-grade education who ran away from home when he was in middle school. He spent much of his early adult life as a drifter, spending time in and out of prisons for nonviolent crimes.
Gideon was charged with breaking and entering with the intent to commit a misdemeanor, which is a felony under Florida law. At trial, Gideon appeared in court without an attorney. He asked the judge to appoint counsel for him because he could not afford an attorney. The trial judge denied Gideon’s request because Florida law only permitted appointment of counsel for poor defendants charged with capital offenses.
At trial, Gideon represented himself He declined to testify himself and made arguments emphasizing his innocence. Despite his efforts, the jury found Gideon guilty and he was sentenced to five years imprisonment.
Gideon sought relief from his conviction by filing a petition for writ of habeas corpus in the Florida Supreme Court. In his petition, Gideon challenged his conviction and sentence on the ground that the trial judge’s refusal to appoint counsel violated Gideon’s constitutional rights. The Florida Supreme Court denied Gideon’s petition.
Gideon filed a petition in the U.S. Supreme Court. The Court agreed to hear the case to resolve the question of whether the right to counsel guaranteed under the Sixth Amendment of the Constitution applies to defendants in state court.
Issue: A prior decision of Betts v. Brady, 316 U.S. 455 (1942), held that the refusal to appoint counsel for an indigent defendant charged with a felony in state court did not necessarily violate the Due Process Clause of the Fourteenth Amendment. The Court unanimously overruled Betts v. Brady.
Reasoning: The Court held that the Sixth Amendment’s guarantee of counsel is a fundamental right essential to a fair trial and, as such, applies to the states through the Due Process Clause of the Fourteenth Amendment. In overturning Betts, Justice Black stated that “reason and reflection require us to recognize that in our adversary system of criminal justice, any person hauled into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided for him.
Source: Gideon v. Wainwright (1963)
Administrative Office of the U.S. Courts