Coleman v. Alabama
Citation and Court
399 U.S. 1 (1970), Supreme Court of the United States
Facts
Two defendants were denied appointed counsel at a preliminary hearing in Alabama. At the hearing, the judge determined whether there was sufficient evidence to bind defendants over to the grand jury. The defendants were later convicted at trial and challenged the denial of counsel at the preliminary stage.
Issue
Whether the Sixth Amendment right to counsel attaches at a preliminary hearing at which a judge determines whether probable cause exists to bind a defendant over to a grand jury.
Holding
A preliminary hearing in Alabama is a “critical stage” of the criminal prosecution at which the Sixth Amendment guarantees the right to counsel.
Rule / Doctrine
The Sixth Amendment right to counsel attaches at all “critical stages” of a criminal proceeding — any stage where the absence of counsel might derogate from the accused’s right to a fair trial. A preliminary hearing is a critical stage because counsel could, among other things, expose weaknesses in the prosecution’s case, make arguments about bail, and develop information useful at trial.
Significance
Coleman extends the critical stage doctrine to preliminary hearings, significantly broadening the point at which the right to counsel attaches. It is a key case in the line from Powell v. Alabama and Gideon v. Wainwright that defines when the Sixth Amendment guarantee is triggered.