Gideon v. Wainwright

Gideon v. Wainwright Case Brief

United States Supreme Court
372 U.S. 335 (1962)

ISSUE: Should Betts v. Brady be overruled as being inconsistent with the fundamental right of fairness at trial?
HOLDING: Yes.
FACTS:
  • Gideon was charged with breaking and entering and asked the court to appoint a lawyer to represent him -- the court refused because it was a non-capital case
  • D conducted his own jury trial and was convicted
REASONING:
  • Overrule Betts: Court in Betts was wrong in concluding that the 6th Amdt.'s guarantee of counsel is not one of the fundamental rights essential to a fair trial
    • Both precedents and reason require one to recognize that in the adversary system, one cannot be assured a fair trial unless counsel is provided for him
    • Lawyers in criminal courts are necessities, not luxuries
COMMENTS:
  • Overrules Betts v. Brady, which held that the assistance of counsel was not a fundamental right of an accused essential to a fair trial.
ADDITIONAL CASES:
  • Carnley v. Cochran: For a waiver of the right to counsel at trial to be valid, the record must show that the accused was offered counsel but intelligently and understandably rejected the offer
  • Faretta v. California: D should be made aware of the dangers and disadvantages of self-representation so that the record will establish that he knows what he is doing and his choice is made with his eyes open
  • McMann v. Richardson: Ineffective assistance of counsel:
    1. Attorney's performance be deficient when measured against an objective standard of reasonableness; AND
    2. D was prejudiced in that there was a reasonable probability that but for counsel's deficient performance, the result of the proceeding would have been different.

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