Powell v. Alabama
Citation: 287 U.S. 45 (1932) Court: United States Supreme Court
Facts
Eight Black teenagers (the “Scottsboro Boys”) were charged with raping two white women in Alabama and faced the death penalty. They were denied meaningful assistance of counsel — attorneys were appointed only moments before trial began and had no opportunity to consult with or prepare a defense for their clients. The defendants were convicted and sentenced to death.
Issue
Does the Due Process Clause of the 14th Amendment require states to provide adequate appointed counsel to indigent defendants charged with capital offenses?
Holding
Yes. The Supreme Court reversed the convictions, holding that the denial of effective assistance of counsel in a capital case violated the Due Process Clause of the 14th Amendment.
Rule / Doctrine
The Due Process Clause requires states to provide counsel to indigent defendants facing capital charges. Appointment of counsel must be more than nominal — it must afford the defendant a fair opportunity to be heard. This is a foundational right-to-counsel ruling predating full incorporation of the 6th Amendment against the states.
Significance
Powell is the first major Supreme Court decision requiring states to provide counsel to defendants facing the death penalty. It laid the groundwork for the eventual incorporation of the 6th Amendment right to counsel and marked the beginning of federal constitutional oversight of state criminal proceedings. The case also became a landmark in the history of racial injustice in the American legal system.