Betts v. Brady
Citation: 316 U.S. 455 (1942) Court: United States Supreme Court
Facts
Smith Betts was charged with robbery in Maryland and requested appointed counsel because he was indigent. The judge denied the request, noting that appointed counsel in Maryland was provided only in murder and rape cases. Betts represented himself, was convicted, and then sought habeas corpus relief, arguing the 14th Amendment required the state to provide him counsel.
Issue
Does the 14th Amendment incorporate the 6th Amendment right to counsel against the states, requiring appointment of counsel in all felony cases?
Holding
No. The Supreme Court held that the 14th Amendment did not require states to appoint counsel in all felony cases; the right to counsel was not a fundamental right applicable to the states in every criminal prosecution.
Rule / Doctrine
The 6th Amendment right to counsel is not incorporated against the states. State capital cases are governed by a case-by-case “special circumstances” test: appointed counsel is required only when denial of counsel would result in a fundamentally unfair trial given the particular facts (e.g., complexity of the charge, mental incapacity of the defendant).
Significance
Betts v. Brady established the “special circumstances” rule that governed state criminal proceedings for over two decades. It was explicitly overruled by Gideon v. Wainwright (1963), which held that the 6th Amendment right to counsel is a fundamental right incorporated against the states through the 14th Amendment and applies in all felony prosecutions.