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A case study of giseon vs wainwright and miranda vs arizona

Facts and Case Summary - Gideon v. Wainwright

An unknown person broke a door, smashed a cigarette machine and a record player, and stole money from a cash register. Later that day, a witness reported that he had seen Clarence Earl Gideon in the poolroom at around 5: Gideon appeared in court alone as he was too poor to afford counsel, whereupon the following conversation took place: Gideon, I am sorry, but I cannot appoint counsel to represent you in this case. Under the laws of the State of Florida, the only time the court can appoint counsel to represent a defendant is when that person is charged with a capital offense.

I am sorry, but I will have to deny your request to appoint counsel to defend you in this case.

  • Two months later the court unanimously ruled that the denial of an attorney violated the Fourteenth Amendment , which guarantees due process;
  • For example, whether a witness's statement should be barred because it was hearsay , is an extremely complicated issue that no lay man could readily confront, and such a situation only arose in the middle of a trial.

The Florida court declined to appoint counsel for Gideon. As a result, he was forced to act as his own counsel and conduct his own defense in court, emphasizing his innocence in the case. At the conclusion of the trial the jury returned a guilty verdict. The court sentenced Gideon to serve five years in the state prison.

From the cell at Florida State Prisonmaking use of the prison library and writing in pencil on prison stationery, [2] Gideon appealed to the United States Supreme Court in a suit against the Secretary of the Florida Department of CorrectionsH. Cochran later retired and was replaced with Louie L. Wainwright before the case was heard by the Supreme Court. Gideon argued in his appeal that he had been denied counsel and, therefore, his Sixth Amendment rights, as applied to the states by the Fourteenth Amendmenthad been violated.

Fortas highlighted, that determination occurred too early in the case to be of any use.

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For example, whether a witness's statement should be barred because it was hearsayis an extremely complicated issue that no lay man could readily confront, and such a situation only arose in the middle of a trial. As a second point, Mr. Fortas presented during oral argument that it was widely accepted in the legal community, that the first thing any reputable lawyer does when he is accused of a crime is hire an attorney.

In providing an example, Mr. Fortas presented the justices with the fact that when Clarence Darrowwho was widely known as the greatest criminal attorney in the United States, was charged with jury tampering and suborning perjury, the first thing he did was get an attorney to represent him.

Fortas suggested, if the greatest attorney in the US needed an attorney to represent him in criminal proceedings, than a man without a legal education or any education for that matter needed a lawyer just the same. The decision was announced as unanimous in favor of Gideon. The Supreme Court decision specifically cited its previous ruling in Powell v.

Whether or not the decision in Powell v. Alabama applied to non-capital cases had sparked heated debate. Brady had earlier held that, unless certain circumstances were present, such as illiteracy or stupidity of the defendant, or an especially complicated case, there was no need for a court-appointed attorney in state court criminal proceedings.

Betts had thus provided selective application of the Sixth Amendment right to counsel to the states, depending on the circumstances, as the Sixth Amendment had only been held binding in federal cases. Wainwright overruled Betts v.

Brady, instead holding that the assistance of counsel, if desired by a defendant who could not afford to hire counsel, was a fundamental right under the United States Constitution, binding on the states, and essential for a fair trial and due process of law regardless of the circumstances of the case. Justice Clark's concurring opinion stated that the Sixth Amendment to the Constitution does not distinguish between capital and non-capital cases, so legal counsel must be provided for an indigent defendant in all cases.

The Supreme Court remanded the case to the Supreme Court of Florida for "further action not inconsistent with this decision.

Wainwright was one of a series of Supreme Court decisions that confirmed the right of defendants in criminal proceedings, upon request, to have counsel appointed both during trial and on appeal.

In the subsequent cases of Massiah v. United States377 U. Implications[ edit ] Approximately 2,000 individuals were freed in Florida alone as a result of the Gideon decision.

The decision did not directly result in Gideon being freed; instead, he received a new trial with the appointment of defense counsel at the government's expense. Fred Turner to be his lawyer in his second trial. The retrial took place on August 5, 1963, five months after the Supreme Court ruling. Turner, during the trial, picked apart the testimony of eyewitness Henry Cook, and in his opening and closing statements suggested that Cook likely had been a lookout for a group of young men who broke into the poolroom to steal beer, then grabbed the coins while they were there.

Turner also obtained a statement from the cab driver who had taken Gideon from Bay Harbor to a bar in Panama City, stating that Gideon was carrying neither wine, beer, nor Coke when he picked him up, even though Cook testified that he had watched Gideon walk from the pool hall to the phone and then wait for a cab.

This testimony completely discredited Cook. The jury acquitted Gideon after one hour of deliberation. After his acquittal, Gideon resumed his previous life and married again some time later.

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He died of cancer in Fort Lauderdale on January 18, 1972, at age 61. Gideon's family in Missouri accepted his body and laid him to rest in an unmarked grave. A granite headstone was added later. The court reversed Betts and adopted rules that did not require a case-by-case analysis, but instead established the requirement of appointed counsel as a matter of right, without a defendant's having to show "special circumstances" that justified the appointment of counsel. The decision created and then expanded the need for public defenders which had previously been rare.

For example, immediately following the decision, Florida required public defenders in all of the state's circuit courts. Several states and counties followed suit.

In it, criminal defense attorneys work on interdisciplinary teams, alongside civil attorneys, social workers, and legal advocates to help clients with not only direct but also collateral aspects of their criminal cases. More recently the American Bar Association and the National Legal Aid and Defender Association have set minimum training requirements, caseload levels, and experience requirements for defenders.

  • In the subsequent cases of Massiah v;
  • Gideon sought relief from his conviction by filing a petition for writ of habeas corpus in the Florida Supreme Court;
  • Gideon cross-examined witnesses, but he was unable to impeach their credibility or point out the contradictions in their testimony;
  • This varies a great deal from federal law, which generally has stricter guidelines for waiving the right to counsel.

Some criticize the mindset in which public defense lawyers encourage their clients to simply plead guilty. Some defenders say this is intended to lessen their own workload, while others would say it is intended to obtain a lighter sentence by negotiating a plea bargain as compared with going to trial and perhaps having a harsher sentence imposed.

Gideon v. Wainwright

You go to work, you get more cases. You have to triage. Maxwell decision demonstrates the differences between how states and the federal government address standards for waiver of the right to counsel. The underlying alleged crime and trial in Doughty took place in Ohiowhich had its own way of interpreting the right to counsel as do many states. Depending upon one's viewpoint, rules such as these could be seen as an attempt by a state to establish reasonable rules in criminal cases or as an attempt to save money even at the expense of denying a defendant due process.

This varies a great deal from federal law, which generally has stricter guidelines for waiving the right to counsel. An analogous area of criminal law is the circumstances under which a criminal defendant can waive the right to trial.

Under federal law, the defendant can only waive his or her right to trial if it is clear that the defendant understands the "charges, the consequences of the various pleas, and the availability of counsel". Gideon's Trumpeta book and TV movie based on this case Gideon's Armya documentary film about public defenders in the American South.