Gideon v. Wainwright
Citation: 372 U.S. 335 (1963)
Facts
Clarence Earl Gideon was charged with breaking and entering a Florida pool hall — a felony under Florida law. Too poor to afford a lawyer, he requested appointed counsel. The trial court denied the request, citing Florida law that only provided counsel in capital cases. Gideon represented himself, was convicted, and filed a handwritten habeas petition to the Supreme Court.
Issue
Whether the Sixth Amendment’s right to counsel is incorporated against the states through the Fourteenth Amendment, requiring states to appoint counsel for indigent defendants in felony cases.
Holding
The Supreme Court unanimously held that the Sixth Amendment right to counsel is a fundamental right incorporated against the states. States must appoint counsel for indigent defendants charged with felonies.
Rule
The Sixth Amendment right to counsel applies to state criminal proceedings through the Fourteenth Amendment. An indigent defendant charged with a felony has the constitutional right to appointed counsel.
Significance
Gideon overruled Betts v. Brady (1942) and fundamentally transformed the American criminal justice system by creating a constitutional entitlement to appointed counsel in all felony cases. It is the foundation of modern public defender systems and one of the most celebrated Supreme Court decisions in criminal procedure.