Johnson v. Zerbst
Citation: 304 U.S. 458 (1938) Court: United States Supreme Court
Facts
Johnson, a federal prisoner, claimed he was denied his right to counsel at his federal criminal trial for counterfeiting. He raised this claim through a habeas corpus petition. He had represented himself at trial without clearly waiving his right to counsel, and the Court was asked whether his conviction could stand.
Issue
Does the 6th Amendment right to counsel apply in all federal criminal proceedings, and what standard governs waiver of that right?
Holding
Yes. The 6th Amendment guarantees the right to counsel in all federal criminal proceedings. Johnson’s habeas petition could succeed if the trial court failed to ensure a proper waiver of counsel.
Rule / Doctrine
The 6th Amendment right to counsel applies to all federal criminal prosecutions. Waiver of the right to counsel must be knowing, intelligent, and voluntary — the defendant must be aware of the right and must deliberately choose to relinquish it. Courts have a duty to indulge every reasonable presumption against waiver of fundamental constitutional rights.
Significance
Johnson v. Zerbst established the foundational standard for waiver of constitutional rights in criminal proceedings — knowing, intelligent, and voluntary — which remains the applicable standard today across many constitutional rights. The case extended the right to counsel to all federal criminal trials (not just capital cases) and confirmed the availability of habeas corpus as a remedy for Sixth Amendment violations.