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In Gideon's first trial, State of Florida v. Clarence Earl Gideon, he was forced to defend himself (pro se) because the Supreme Court ruled in Betts v. Brady, (1942) that the states didn't have to provide court-appointed counsel to indigent criminal defendants. The Supreme Court overturned this decision in Gideon v. Wainwright, 372 US 335 (1963).

Gideon's attorney in the Supreme Court case was future justice Abe Fortas; his attorney at his second trial was Fred W. Turner.

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