Addendum specifications and requirements

Court Case

Why did the court feel it was necessary to overturn Betts v. Brady in the Gideon v. Wainwright case?

Background of Gideon v. Wainwright (1963) was that Clarence Earl Gideon, a penniless Florida drifter, was charged in a Florida state court with a non-capital felony for breaking and entering a poolroom; unable to hire a lawyer for his defense, he requested the court to appoint an attorney for him. The court refused, stating that it was only obligated to appoint counsel to indigent defendants in capital cases. Gideon defended himself in the trial; was convicted by a jury and given a five-year prison sentence. His appeal to the State Supreme Court was rejected and he then appealed to the U.S. Supreme Court (Gideon v. Wainwright, 1963-- Find Law).

The Gideon case was substantially similar to an earlier case decided twenty years earlier by the U.S. Supreme Court, i.e., Betts v. Brady in which Smith Betts, a 43-year-old unemployed man, was indicted for robbing a store in Carroll County, Maryland; the trial court had denied the defendant's request for an attorney on the grounds that the State of Maryland commonly appointed counsel only in prosecutions for capital offense cases such as murder and rape. Having been found guilty and sentenced to eight years in prison, his appeals to the Circuit Court and the Court of Appeals were rejected and Betts appealed to the U.S. Supreme Court for a review. In a 6-3 verdict, the Court held that the Sixth Amendment applied only to trials in federal courts; and it was not incumbent upon a state, in cases that did not involve capital punishment, to provide counsel for a defendant who could not afford one (Betts v Brady, 1942-- Find Law).

In the United States, courts generally make decisions based on the precedent that has been established in earlier cases. Hence, the Supreme Court's own decision in Betts v. Brady (1942), being a substantially similar case as Gideon, could not be ignored by the Court and was bound to be a major factor in the Court's decision in Gideon. However, it is also a fact that the Supreme Court decision in Betts v. Brady was not without controversy. To begin with, it was not a unanimous decision. It was marked by a ringing dissenting opinion by Justice Hugo Black who had passionately differed with the majority opinion and observed:

practice cannot be reconciled with 'common and fundamental ideas of fairness and right', which subjects innocent men to increased dangers of conviction merely because of their poverty. Whether a man is innocent cannot be determined from a trial in which, as here, denial of counsel has made it impossible to conclude, with any satisfactory degree of certainty, that the defendant's case was adequately presented.

Quote from Justice Black's dissenting opinion, Betts v Brady, 1942-- from Find Law)