Gideon v. Wainwright

Facts

The State of Florida charged Gideon in a state court with breaking and entering a poolroom with intent to commit a misdemeanor, an offense defined as a felony under Florida law. Gideon appeared in court without funds and without a lawyer. He asked the trial court to appoint counsel to represent him. The trial judge refused his request, explaining that under Florida law the court could appoint counsel to represent a defendant only when that person was charged with a capital offense. Gideon replied that the Supreme Court of the United States said he was entitled to counsel. Forced to defend himself, Gideon was tried before a jury. He conducted his defense about as well as could be expected from a layman: he delivered an opening statement to the jury, cross-examined the State’s witnesses, called witnesses in his defense, chose not to testify himself, and made a short argument emphasizing his innocence. The jury returned a verdict of guilty. The trial court sentenced Gideon to serve five years in the state prison.

Issues

1. Does the Fourteenth Amendment make the Sixth Amendment guarantee of counsel obligatory on the States, requiring state courts to provide counsel for indigent defendants facing felony charges?
2. Should the Court overrule Betts v. Brady, which concluded that appointment of counsel for an indigent defendant charged with a felony is not a fundamental right essential to a fair trial?

Holding

Betts v. Brady is overruled. The Sixth Amendment's guarantee of counsel is a fundamental right, essential to a fair trial, so the Fourteenth Amendment made it obligatory on Florida, and the Constitution guaranteed Gideon, who came to court without funds and asked for a lawyer, the assistance of counsel at his felony trial.