Gideon v. Wainwright (1963)
Clarence Earl Gideon
Facts of the Case:
Gideon was charged in a Florida state court with a felony for breaking and entering. He lacked
funds and was unable to hire a lawyer to prepare his defense. When 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; he was
convicted by a jury and the court sentenced him to five years in a state prison.
Question:
Did the state court's failure to appoint counsel for Gideon violate his right to a fair trial and due
process of law as protected by the Sixth and Fourteenth Amendments?
Conclusion:
In a unanimous opinion, the Court held that Gideon had a right to be represented by a courtappointed attorney and, in doing so, overruled its 1942 decision of Betts v. Brady. In this case
the Court found that the Sixth Amendment's guarantee of counsel was a fundamental right,
essential to a fair trial, which should be made applicable to the states through the Due Process
Clause of the Fourteenth Amendment. Justice Black called it an "obvious truth" that a fair trial
for a poor defendant could not be guaranteed without the assistance of counsel. Those familiar
with the American system of justice, commented Black, recognized that "lawyers in criminal
courts are necessities, not luxuries."
Decisions
Decision: 9 votes for Gideon, 0 vote(s) against
Legal provision: Right to Counsel
Miranda v. Arizona (1966)
Ernesto Miranda
Facts of the Case:
The case began with the 1963 arrest of Phoenix resident Ernesto Miranda, who was charged with
rape, kidnapping, and robbery. Miranda was not informed of his rights prior to the police
interrogation. During the two-hour interrogation, Miranda allegedly confessed to committing the
crimes, which the police apparently recorded. Miranda, who had not finished ninth grade and had
a history of mental instability, had no counsel present. At trial, the prosecution's case consisted
solely of his confession. Miranda was convicted of both rape and kidnapping and sentenced to 20
to 30 years in prison. He appealed to the Arizona Supreme Court, claiming that the police had
unconstitutionally obtained his confession. The court disagreed, however, and upheld the
conviction. Miranda appealed to the U.S. Supreme Court, which reviewed the case in 1966.
Question:
Does the police practice of interrogating individuals without notifying them of their right to
counsel and their protection against self-incrimination violate the Fifth Amendment?
Conclusion:
In Miranda v. Arizona (1966), the Supreme Court ruled that detained criminal suspects, prior to
police questioning, must be informed of their constitutional right to an attorney and against selfincrimination. The Supreme Court decision written by Chief Justice Earl Warren, ruled that the
prosecution could not introduce Miranda's confession as evidence in a criminal trial because the
police had failed to first inform Miranda of his right to an attorney and against self-incrimination.
The police duty to give these warnings is compelled by the Constitution's Fifth Amendment,
which gives a criminal suspect the right to refuse "to be a witness against himself," and Sixth
Amendment, which guarantees criminal defendants the right to an attorney.
Decisions
Decision: 5 votes for Miranda, 4 vote(s) against
Legal provision: Self-Incrimination