Gideon v. Wainwright

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372 U.S. 335 (1963), argued 15 Jan. 1963, decided 18 Mar. 1963 by vote of 9 to 0; black for the Court, Douglas, Clark, and Harlan concurring. Clarence Earl Gideon was charged with breaking and entering a poolroom with intent to commit a misdemeanor, a felony under Florida law. Being without funds, Gideon requested that counsel be appointed for him; the Florida trial court refused and Gideon conducted his own defense “about as well as could be expected from a layman” (p. 337). The jury returned a verdict of guilty. Gideon filed a habeas corpus petition in the Florida Supreme Court claiming that his federal constitutional rights had been abridged by the trial court's refusal to appoint counsel for him; the Florida Supreme Court denied relief and Gideon appealed in forma pauperis to the U.S. Supreme Court.

The Court appointed Abe Fortas, a prominent lawyer who later served as a justice, to argue Gideon's case and address whether Betts v. Brady (1942) should be overruled. Betts had held that, in state courts, the Fourteenth Amendment's Due Process Clause only required that appointed counsel be provided to indigents in special circumstances. However, the Court had not upheld a single denial of right to counsel under the Betts rule since its 1950 decision in Quicksal v. Michigan. The Court was looking for an opportunity to overrule Betts, and Gideon provided that opportunity.

A unanimous Court overruled Betts and held that the Sixth Amendment, as applied to the states by the Fourteenth Amendment, required that counsel be appointed to represent indigent defendants charged with serious offenses in state criminal trials. At his retrial, Gideon was represented by appointed counsel who uncovered new defense witnesses and discredited prosecution witnesses; a new jury acquitted Gideon.

In overruling Betts, Justice Hugo Black, for the majority, argued that the Court was “returning to … old precedents, sounder we believe than the new” (p. 334). In Powell v. Alabama (1932), the Court had held that when an indigent defendant is charged with a capital offense in a state court and is incapable of making his own defense, due process requires that counsel be appointed for him. It noted that “the right to be heard would be of little avail if it did not comprehend the right to be heard by counsel” (p. 68). In Johnson v. Zerbst (1938), the Court declared a right to appointed counsel in federal criminal cases. By 1942, thirty‐five states required that counsel be appointed to represent indigents in serious noncapital as well as capital cases. Indeed, in Gideon twenty‐two states filed an amicus curiae brief urging reversal of Betts and only three states, including Florida, argued that Betts should be upheld.

Gideon was widely interpreted as applying only to felony cases; but, in Argersinger v. Hamlin (1972), the Court extended the right to appointed counsel to misdemeanors when the defendant is sentenced to imprisonment. In another case decided the same day as Gideon, Douglas v. California, the Court held that the Equal Protection Clause conferred a right to appointed counsel for first appeals of right. In subsequent years, Gideon spawned two lines of cases. One series of cases deals with the Sixth Amendment right to counsel and at what stages of the criminal justice process the defendant must be allowed the benefit of counsel. Another line of cases acknowledges that the right to counsel implies the right to effective counsel and attempts to develop standards for determining when that right had been denied.

Today, most large cities and some states have public defender offices that provide counsel to indigents in criminal cases. In other regions, trial court judges appoint private attorneys to represent indigent defendants. A 1984 Department of Justice survey reported that two‐thirds of the nation's population is served by public defenders. Various studies have shown that a defendant's chance of being convicted is not significantly affected by whether he is represented by a public defender or private counsel, although defendants who proceed without counsel are significantly more likely to be convicted. Gideon, along with Mapp v. Ohio (1961), marked the beginning of the Court's “due process revolution,” which resulted in the constitutionalization of state criminal procedure and a series of only partially successful attempts to convince the Court to extend due process guarantees to civil and quasi‐legal proceedings.

See also Counsel, Right to; Sixth Amendment.

Bibliography

• Anthony Lewis, Gideon's Trumpet (1964)

— Susan E. Lawrence

• 372 U.S. 335 (1963)
• Vote: 9–-0
• For the Court: Black
• Concurring: Clark, Douglas, and Harlan

Clarence Earl Gideon, a penniless Florida drifter, was arrested for the burglary of a Florida pool hall. At his trial Gideon asked for a court-appointed attorney because he could not afford a lawyer. The court denied Gideon's request, and he conducted his own defense.The Florida court convicted Gideon and sentenced him to five years in prison. In his jail cell, using a pencil and pad of paper, Gideon composed a petition asking the Supreme Court to review his case.

“The question is very simple,” wrote Gideon. “I requested the [Florida] court to appoint me an attorney and the court refused.” He maintained that the state court's refusal to appoint counsel for him denied him rights “guaranteed by the Constitution and the Bill of Rights” in the 6th and 14th Amendments. The Supreme Court decided to review Gideon's case. Unlike the Florida court, however, the Supreme Court did not expect Gideon to argue his own case. Instead, the Court appointed Abe Fortas, a prominent Washington lawyer and a future Supreme Court justice, to argue Gideon's case. Fortas defended Gideon pro bono publico (for the good of the public), donating his time and money for the cause of justice.

The Issue

The 6th Amendment states that “in all criminal prosecutions the accused shall enjoy the right…to have the assistance of counsel for his defense.”

Despite the unmistakably clear meaning of this wording, the Supreme Court had ruled in earlier cases that in state courts, needy defendants had a constitutional right to court-appointed lawyers in only two situations: in cases involving the death penalty (Powell v. Alabama, 1932) and in cases where special circumstances, such as youth or mental incompetence, required furnishing an attorney to assure a fair trial (Betts v. Brady, 1942).

Does the 6th Amendment right to counsel apply to all criminal cases? Does the due process clause of the 14th Amendment require states to provide lawyers for defendants too poor to hire their own attorneys? Or should the Court continue to follow the precedent set in Betts v. Brady? The Supreme Court asked the attorneys arguing the Gideon case specifically to consider whether it should overrule Betts v. Brady.

Opinion of the Court

The Court ruled unanimously in Gideon's favor and did overrule Betts v. Brady. The Court held that the right to counsel was so fundamental that the 14th Amendment due process clause extended the 6th Amendment guarantee of counsel to all defendants in criminal cases.

Justice Hugo Black, who had written a dissenting opinion in Betts v. Brady 21 years before, now had the pleasure of writing the Court's opinion to overturn the Betts decision.

Significance

As a result of the ruling, the state of Florida granted Clarence Earl Gideon a new state trial in August 1963. Represented by a court-appointed lawyer, Gideon was found not guilty. The Supreme Court's decision also caused states throughout the nation to review numerous cases. Defendants too poor to afford attorneys' fees, who had been tried without the benefit of counsel, received retrials. The courts acquitted many and released them from prison.

The Gideon case reflected the emergence of a nationwide concern with equal justice for the poor. It recognized that, left without the aid of counsel, even intelligent and educated people have very little chance of successfully defending themselves in criminal trials. Most large cities and some states have public defender offices that provide free legal help to poor people in criminal cases. In other areas, trial court judges appoint private lawyers to represent poor defendants.

See also Betts v. Brady; Powell v. Alabama; Rights of the accused; Counsel, right to

Sources

• Anthony Lewis, Gideon's Trumpet (New York: Random House, 1964)

In Powell v. Alabama (1932) the U. S. Supreme Court held that state prosecution of indigent defendants for a capital crime without effective appointment of defense counsel violated the due process clause of the Fourteenth Amendment to the Constitution of the United States. But in Betts v. Brady (1942) the Court declined to compel the states to provide counsel in noncapital cases without "special circumstances" that would render a trial without counsel "fundamentally unfair." In 1962, the year Clarence Earl Gideon was prosecuted for burglary in a Florida state court, about a dozen states, including Florida, failed to meet the minimum constitutional requirements of Betts. Gideon was forced to defend himself and was convicted, despite his insistence at trial that "the U. S. Supreme Court says I am entitled to counsel." A year later, in Gideon v. Wainwright (372 U. S. 335), the Supreme Court agreed with him. Overruling Betts, it held that at least in all felony cases "any person …too poor to hire a lawyer cannot be assured a fair trial unless counsel is provided for him."

The political reaction to Gideon was generally favorable. Many states implemented the decision by establishing public defender systems or greatly expanding existing ones. The limitation of Gideon to felony cases was rejected in 1972, when the Supreme Court held that no person may be imprisoned for any offense without representation by counsel (Argersinger v. Hamlin, 407 U. S. 25, 37).

Bibliography

Beaney, William Merritt. The Right to Counsel in American Courts. Ann Arbor: University of Michigan Press, 1955.

Lewis, Anthony. Gideon's Trumpet. New York: Random House, 1964.

—Yale Kamisar/A. R.

Gideon v. Wainwright, 372 U.S. 335, 83 S. Ct. 792, 9 L. Ed. 2d 799, is a 1963 U.S. Supreme Court decision that established an indigent criminal defendant's right, under the Sixth Amendment of the U.S. Constitution, to counsel in state criminal trials.

In 1961, Clarence Earl Gideon was charged in a Florida state court with breaking into and entering a poolroom with intent to commit a misdemeanor, a combination of offenses that constituted a felony under Florida law. He could not afford a lawyer, and he requested to have one appointed by the court. Nearly twenty years earlier, the U.S. Supreme Court had held in Betts v. Brady, 316 U.S. 455, 62 S. Ct. 1252, 86 L. Ed. 1595 (1942), that an ordinary person could do an adequate job of defending himself or herself. A court-appointed lawyer was required only if the defendant had mental or physical deficiencies, the case was unusually complicated, or the case involved "special circumstances." None of these exceptions applied to Gideon, the Florida trial court ruled, and thus his request for counsel was denied.

Gideon conducted his own defense and was found guilty of the charges. He then filed a handwritten petition with the Supreme Court of Florida, seeking to overturn his conviction on the ground that the trial court's refusal to appoint an attorney for him denied him the rights "guaranteed by the Constitution and the Bill of Rights by the United States Government." The state supreme court denied Gideon's petition.

While in prison, Gideon, using law books available to him, drafted a petition for writ of certiorari to the U.S. Supreme Court. (The petition is the legal document in which a person requests the Supreme Court to hear an appeal. The Court has the discretion to accept or decline the appeal.) According to Anthony Lewis's acclaimed book on the case, Gideon's Trumpet (1964), in the handwritten petition Gideon stated that it "just was not fair" that he had no lawyer at his trial. The petition was granted, and Abe Fortas, who would later serve as an associate justice on the Court, was appointed to argue Gideon's case.

In a unanimous decision, the Supreme Court overruled Betts, holding the guarantee of counsel to be a fundamental right under the U.S. Constitution. The Court ruled that the Due Process Clause of the Fourteenth Amendment required that the Sixth Amendment, which guarantees indigent defendants the right to counsel in federal criminal proceedings, be interpreted to include indigent defendants in state criminal trials. In his majority opinion, Justice Hugo L. Black wrote, "[R]eason and reflection require us to recognize that in our … system of criminal justice, any person hailed into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided." Black further pointed out that the government hires attorneys to prosecute defendants, and individuals charged with crimes who are financially able hire attorneys to defend them, both "strong indications … that lawyers in criminal courts are necessities, not luxuries."

Gideon was later retried with a court-appointed lawyer representing him and was found not guilty.

Following Gideon, it was unclear whether the decision applied only to indigent defendants facing felony convictions and not to individuals charged with lesser crimes. Nine years later, that issue was clarified in Argersinger v. Hamlin, 407 U.S. 25, 92 S. Ct. 2006, 32 L. Ed. 2d 530 (1972). In Argersinger, the Supreme Court expanded its holding in Gideon, ruling that the Sixth Amendment right to appointed counsel extended to misdemeanor cases in which the person charged may face imprisonment, unless the defendant makes a "knowing and intelligent waiver" of her or his right to counsel. The Court concluded that an accused in a misdemeanor trial likewise has a strong need for representation and that Gideon should apply "to any criminal trial, where an accused is deprived of his liberty."

Argersinger was limited a few years later by Scott v. Illinois, 440 U.S. 367, 99 S. Ct. 1158, 59 L. Ed. 2d 383 (1979). In Scott, the Supreme Court held that the Sixth Amendment right to counsel extends only to cases where "actual imprisonment" is imposed, and not to cases where the "mere threat of imprisonment" exists (where the crime charged authorizes a possible jail sentence).

See: criminal procedure; due process of law; public defender.

Gideon v. Wainwright
Supreme Court of the United States
Argued January 15, 1963 Decided March 18, 1963
Full case name	Clarence E. Gideon v. Louie L. Wainwright, Corrections Director
Citations	372 U.S. 335 (more) 83 S. Ct. 792; 9 L. Ed. 2d 799; 5951 U.S. LEXIS 1942; 23 Ohio Op. 2d 258; 93 A.L.R.2d 733;
Prior history	Defendant convicted, Bay County, Florida Circuit Court (1961); habeas petition denied w/o opinion, sub. nom. Gideon v. Cochrane, 135 So. 2d 746 (Fla. 1961)
Subsequent history	On remand, 153 So. 2d 299 (Fla. 1963); defendant acquitted, Bay County, Florida Circuit Court (1963)
Argument	Oral argument
Holding
The Sixth Amendment right to counsel is a fundamental right applied to the states via the Fourteenth Amendment's due process clause, and requires that indigent criminal defendants be provided counsel at trial. Supreme Court of Florida reversed.
Court membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan, Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Black, joined by Warren, Douglas, Brennan, Stewart, White, Goldberg
Concurrence	Douglas
Concurrence	Clark
Concurrence	Harlan
Laws applied
U.S. Const. amends. VI, XIV

Gideon v. Wainwright, 372 U.S. 335 (1963), is a landmark case in United States Supreme Court history. In the case, the Supreme Court unanimously ruled that state courts are required under the Sixth Amendment of the Constitution to provide counsel in criminal cases for defendants unable to afford their own attorneys.

Contents 1 Background of the Case 2 Decision 3 Aftermath 3.1 Impact on courts 3.2 Public defender system 3.3 Right to counsel 4 Modern era 4.1 Expansion efforts 4.2 Problems 5 See also 6 References 7 Further reading 8 External links

Background of the Case

Between midnight and 8:00 am on June 3, 1961, a burglary occurred at the Bay Harbor Pool Room in Panama City, Florida. Someone broke a door, smashed the soda machine and record player, and stole money from a register. Later that day, a witness reported that he had seen Clarence Earl Gideon in the poolroom at around 7:30 that morning leaving with a wine and money in his pockets. Based on this accusation alone, the police arrested him and charged him with breaking and entering and petty larceny.

The Supreme Court had ruled in Powell v. Alabama, 287 U.S. 45 (1932), the famous case of the Scottsboro Boys, that the right to counsel was implied in the Bill of Rights and was an essential freedom. In Betts v. Brady, 316 U.S. 455 (1942), the Court had modified this doctrine slightly, ruling that whether or not a lawyer was required depended on the circumstances of each case. Specifically, the Court focused on a case-by-case determination if the lack of representation affected a denial of due process, thus rendering the trial unfair. Over the next twenty years, the Court heard several more cases and in all of them ruled that, in fact, a lawyer was required. Due to the difficulty of proving the high standard of a due process error, nearly all such cases involved the death penalty. This view had not changed by the early 1960s.

Gideon appeared in court and was too poor to afford counsel, whereupon the following conversation took place:

The COURT: Mr. 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.

GIDEON: The United States Supreme Court says I am entitled to be represented by Counsel.

Gideon was forced, therefore, to act as his own counsel and conduct a defense of himself in court, emphasizing his innocence in the case. Nevertheless, the jury returned a guilty verdict, sentencing him to serve five years in the state penitentiary.

From his prison cell at Florida State Prison, making use of the prison library and writing in pencil on prison stationery, Gideon appealed to the U.S. Supreme Court in a suit against the Secretary to the Florida Department of Corrections, Louie L. Wainwright. He argued that he had been denied counsel and, therefore, his Sixth Amendment rights, as applied to the states by the Fourteenth Amendment, had been violated.

The court assigned him a prominent Washington, D.C. attorney, Abe Fortas of the law firm Arnold Fortas & Porter, a future Supreme Court justice. Bruce Jacob argued the case for respondents.

Decision

The decision was announced on 18 March 1963; the opinion of the Court was delivered by Justice Hugo Black. The three concurring opinions were written by Justices Clark, Douglas and Harlan.

In it, the court specifically praised its previous ruling in Powell v. Alabama, and overruled Betts v. Brady, which allowed selective application of the Sixth Amendment right to counsel to the states, itself previously binding only in federal cases. Instead, the court held that the right to the assistance of counsel was a fundamental right, essential for a fair trial, thereby emphasizing the procedural safeguards which were needed for due process of law. In this sense, the meaning is specifically that no one, regardless of wealth, education or class, should be charged with a crime and then be forced to face his accusers in court without the guidance of counsel.

Justice Clark's concurrent opinion stated that the Constitution never says whether a case is capital and non capital, so legal counsel needs to be provided in all cases. Justice Harlan's concurrent opinion stated that the mere existence of a serious criminal charge constituted in itself special circumstances requiring the services of counsel at trial.

The court remanded the case to the Supreme Court of Florida for "further action not inconsistent with this decision." Gideon was then retried: represented by W. Fred Turner, his appointed counsel in this second trial, he was acquitted.

Gideon v. Wainwright was one of a series of Supreme Court decisions which confirmed the right of defendants in criminal proceedings to counsel during trial, on appeal, and in the subsequent cases of Massiah v. United States, 377 U.S. 201 (1964) and Miranda v. Arizona 384 U.S. 436 (1966), even during police interrogation.

Aftermath

Impact on courts

The former arrangement of upholding the “fair trial” system, where the state was given a fair amount of latitude in criminal proceedings as long as there were no “shocking departures from fair procedure” was quickly being discarded in favor of a firm set of “…procedural guarantees…” stemming from previous constitutional amendments.^[1] As a result, when Gideon came before the court they decided to reverse Betts and took upon a system of rules that did not require a case-by-case analysis, but instead created the necessary procedure by its very nature.^[1] In this way, the case helped to refine stare decisis: when it should be upheld and what standard should case decisions be tested against precedent to achieve a legitimate practicability in the eyes of the Supreme Court and lower courts.^[2] This confusion resulted in several new methods practiced by the Supreme Court when overturning a previous ruling to maintain the “…impersonal qualities of the judicial process…” and keep the sense that legal system is without feeling or prejudice and simply applies justice to those who come before it.^[3]

Public defender system

Many changes have been made in the prosecution and legal representation of indigent defendants since the Gideon ruling was handed down in 1963. The decision in Gideon created and expanded public defenders. Immediately following the decision, Florida required that public defenders must work in all sixteen of the state's circuit courts.^[4] The need for more public defenders also led to a need to ensure that the defenders are properly trained in legal defense to allow defendants to receive as fair of a case as possible. Several states and counties followed suit. Washington D.C., for instance, is one such city that has created a training program for their public defenders. Public defenders in District of Columbia must receive rigorous training before they are allowed to represent defendants, and they must continue their training in order to remain current and up-to-date.^[5] Another program in the Bronx in New York City requires public defenders to undergo training and provides defendants with “holistic training.”^[5] Recently the American Bar Association and the National Legal Aid and Defender Association set minimum training requirements, caseload levels, and experience requirements for its lawyers.^[5]

Right to counsel

Among the states, the Doughty v. Maxwell decision demonstrates the differences between how state and federal governments address the waiver standards of the right to counsel. In this case the Supreme Court granted certiorari and reversed the decision in Doughty v. Sacks, which held that regardless of Gideon, the defendant waives his or her right to counsel by entering a plea of guilty. Doughty took place in Ohio, which had its own way of interpreting the right to counsel as many states do, including Pennsylvania, West Virginia, and Florida. Pennsylvania and West Virginia also deemed that the right to counsel was waived when a plea of guilty was entered. In Florida, at least before Gideon, the defendant had to request the right to counsel; otherwise, it was automatically waived. This varies a great deal with federal law which has strict guidelines for waiving the right to counsel. 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."^[6]

Modern era

Expansion efforts

There are modern reform efforts that are aiming to expand the Gideon decision to include cases regarding property. In August 2006, the American Bar Association urged states to provide a lawyer for low-income people in categories of civil proceeding involving shelter, sustenance, safety, health, or childcare.^[7] The President of the American Bar Association stated that in regards to civil matters “poor litigants have basic human needs which deserve as much attention as the interest in liberty found to be the basic of criminal right to counsel in Gideon.”^[7] The decision of how this will proceed is not yet finalized, but it is proposed that each state will have a say in which rights should be recognized by legislation.^[7]

Problems

In 2008, The New York Times reported that public defenders' offices around the country were so swamped with cases that they were refusing to take new clients, asserting that if they did so, their clients would not be able to receive the time or attention necessary for competent counsel.^[8] In September 2008, a judge in Florida ruled that Miami-Dade County public defenders could decline requests for defense from those accused of lesser felonies, saving their time and attention for those clients accused of more serious crimes. Miami public defenders in charge of felony cases now defend 500 cases a year, up from 367, and those who handle misdemeanor trials have upwards of 2,000 cases on their docket. The state appealed the judge's ruling in the Miami-Dade case, because if it is upheld, they will have to contract with private-practice attorneys to provide public defenders to clients, at much greater expense to the state.^[8]

Some criminal justice experts believe public defense is deteriorating around the country, which could lead to innocent clients pressured to plead guilty or convicted due to a weak defense. Those who appeal their cases and cite inadequate defense have a hard time getting convictions overturned.^[8]

Florida State Senator Victor Crist believes that public defenders' offices should charge their clients fees, even if the payments had to be delayed. In Missouri, the state defenders' office has been allowed to decline misdemeanor cases or those which will not result in prison time for the defendant.^[8]

Kentucky's state public advocate, Ed Monahan, said: “Since Gideon, I don’t remember a time when the challenges to adequate representation have been so great.” Michigan requires counties to defend the accused, but it does not provide any state funds to do so. Some counties don't provide a lawyer for misdemeanor offenses; in some counties, judges hire attorneys for a flat fee, which a report from the Legal Aid Society claims encourages attorneys to skimp on defense. The state government is already having problems meeting budgets and has no funds to provide the cities and counties for legal defense.^[8]

See also

• Gideon's Trumpet
• List of United States Supreme Court cases, volume 372
• Miranda warning

References

1. ^ ^{a b} Beaney, William M. (1963). "The Right to Counsel: Past, Present, and Future". Virginia Law Review 49 (6): 1150–1159 [p. 1153]. doi:10.2307/1071050. 
2. ^ Israel, Jerold H. (1963). "Gideon v. Wainwright: The ‘Art’ of Overruling". The Supreme Court Review 1963: 211–272 [p. 218]. doi:10.2307/3108734. 
3. ^ Israel (1963), p. 219.
4. ^ "Gideon’s Promise, Still Unkept". The New York Times. 1993-03-18. http://query.nytimes.com/gst/fullpage.html?res=9F0CE7DA1431F93BA25750C0A965958260. Retrieved on 2008-08-08. 
5. ^ ^{a b c} Abel, Laura. “2006 Edward v. Sparer Symposium: Civil Gideon: Creating a Constitutional Right to Counsel in the Civil Context: A Right to Counsel in Civil Cases: Lessons from Gideon v. Wainwright.” Temple Political & Civil Rights Law Review, Volume 15. Summer 2006.
6. ^ ——— (1964). "Waiver of the Right to Counsel in State Court Cases: The Effect of Gideon v. Wainwright". University of Chicago Law Review 31 (3): 591–602. doi:10.2307/1598554. 
7. ^ ^{a b c} Dana, Howard H., Jr. (2006). "2006 Edward v. Sparer Symposium: Civil Gideon: Creating a Constitutional Right to Counsel in the Civil Context: Introduction: ABA 2006 Resolution on Civil Right to Counsel". Temple Political & Civil Rights Law Review 15. 
8. ^ ^{a b c d e} Eric Eckholm (November 8, 2008). "Citing Workload, Public Lawyers Reject New Cases". The New York Times. http://www.nytimes.com/2008/11/09/us/09defender.html?ref=todayspaper. Retrieved on 2008-11-10. 

Further reading

• ——— (2000). "Gideon's Promise Unfulfilled: The Need for Litigated Reform of Indigent Defense". Harvard Law Review 113 (8): 2062–2079. doi:10.2307/1342319. 
• Uelmen, Gerald F. (1995). "2001: A Train Ride: A Guided Tour of the Sixth Amendment Right to Counsel". Law and Contemporary Problems 58 (1): 13–29. doi:10.2307/1192165. 
• Van Alstyne, William W. (1965). "In Gideon's Wake: Harsher Penalties and the ‘Successful’ Criminal Appellant". Yale Law Journal 74 (4): 606–639. doi:10.2307/794613. 

External links

• Gideon v. Wainwright, 372 U.S. 335 (1963) (opinion full text).
• Gideon v. Wainwright, 372 U.S. 335, 1963 Indigent's Right To Appointed Counsel
• History of Office of Public Defender, Second Judicial Circuit – Leon County Florida

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