Supreme Court Case Review
The Rights of the Accused
five cases presented
1. Powell v. Alabama (1932)
While traveling on a train, a fight broke out between a
group of white youths and black youths. The black
youths were arrested and indited in Scottsboro,
Alabama for rape (an accusation was made by a few
young white girls).
The young men were guarded by the militia (for their
safety) unable to contact friends / relatives, assigned
local lawyers to assist at their arraignment, but no
lawyers showed up for the trial.
Trials were quick, lasted one day, and all found guilty. All
were sentences to death (instead of 10 years).
Powell v. Alabama (1932)
Alabama Supreme Court upheld verdict and
sentence. At issue were
– the defendants were not given a fair and impartial
trial
– They were denied the right to counsel, particularly
the chance to consult and prepare a defense before
the trial
– they were tried by all-white juries, from which
qualified African Americans were excluded
Powell v. Alabama (1932)
Supreme Court focused on the 2nd issue - the right to
counsel; Did the failure to provide the defendants with
counsel violate their rights to due process guaranteed
by the Fourteenth Amendment?
Conviction overturned - 7 to 2 majority. Sent the case
back for new trials.
Established that certain fundamental principles of
fairness must be adhered to if justice is to be served.
Includes appointing court appointed attorneys for
defendants whose individual circumstances made it
unlikely that could defend themselves.
2. Betts v. Brady (1942)
Smith Betts, 43 yr. Old unemployed farm worker,
charged with robbery in Carroll County, Maryland. Too
poor to afford counsel, Betts asked the judge to
appoint a local attorney as counsel. The judge
refused because the local practice was to just appoint
counsel for murder or rape.
Betts defended himself, was convicted of robbery.
Betts appeals to highest state court. States he was
denied his Sixth Amendment right to counsel and his
Fourteenth Amendment right to due process
Betts v. Brady (1942)
Chief Judge Carroll Bond refused, stating that the
right to counsel was not a fundamental right and
that the Sixth Amendment did not apply to the
states. He also pointed out that Betts was not
helpless, had reasonable intelligence and not
completely unfamiliar with court procedures
Betts appeals to the Supreme Court
Betts v. Brady (1942)
At issue was the convicted person’s rights under the
Sixth and Fourteenth Amendments.
A 6-3 vote affirming the decision of the Maryland state
courts. Agreeing with Judge Bond, ruled the due
process clause of the Fourteenth Amendment does
not necessarily extend the Sixth Amendment to state
courts.
Thus, state courts not always required to provide lawyers
for the accused. Court appointed attorney’s should be
used for capital crimes or in special circumstances.
Illiterate or mentally handicapped defendants.
3. Gideon v. Wainwright (1963)
Clarence Gideon, 52 year old drifter, arrested for
breaking into a pool hall in Panama City, Fl. He asked
the judge to appoint him an attorney, but under Fl.
Law, he could appoint counsel only in capital crimes.
Gideon conducted his own defense.
Found guilty and sent to prison for 5 years. Fl. State
Supreme Court denied his appeal.
In a handwritten letter, he appealed to the US Supreme
Court on the grounds that his right to counsel under
the Sixth & Fourteenth Amendments had been
violated.
Gideon v. Wainwright (1963)
Betts required counsel for capital cases & special
circumstances, making Gideon a likely case to
reexamine the Court’s ruling.
The question…should the Court overrule Betts v. Brady
and declare that the due process clause of the
Fourteenth Amendment obligates states to apply the
Sixth Amendment in all criminal cases?
Two other states submitted briefs asking the Court to
uphold Betts, but 22 state asked the court to overrule
it.
Gideon v. Wainwright (1963)
The Court ruled unanimously to overrule Betts v.
Brady. It declared the Fourteenth Amendment
obligated the states to follow the Sixth
Amendment and provide counsel to indigent
defendants in all criminal trial.
Justice Hugo Black, who 21 years before, had
been one of the dissenting justices in the Betts
decision, wrote the unanimous opinion.
4. Escobedo v. Illinois (1964)
Danny Escobedo arrested for killing his brother-in-law at
2:30am w/o warrant, taken to Chicago police
headquarters for questioning. He made no statement
and was later released. Ten days later, he was
arrested again. He asked to have his lawyer present,
the request was denied. The police questioned him
for several hours & claimed they had another man
who said Escobedo had fired the shots.
Escobedo’s attorney was in the police station on an
unrelated matter and asked to see his client. The
police denied access until after questioning.
Escobedo v. Illinois (1964)
As the police continued to interrogate Escobedo, they
told him they had DiGerlando (who claimed that
Escobedo killed his brother-in-law) in custody, and
would he like to call him a liar to his face. In the
meeting, Escobedo said, “I didn’t shoot Manuel, you
did”, placing Escobedo at the crime scene.
For the rest of the questioning, Escobedo said things
that would incriminate himself, his sister, and
DiGerlando.
Escobedo v. Illinois (1964)
At trial and appeal, Escobedo asked that all statements
given prior to counsel with his lawyer be suppressed.
Motion was denied as they deemed his statements
were given voluntarily. Escobedo was convicted of
murder.
On appeal to the Supreme Court, the question was…
Was the refusal by police to honor Escobedo’s request
for a lawyer a violation of his Sixth Amendment rights?
5 to 4 vote, overruled the conviction, the information was
not admissible because it had been unlawfully
obtained.
5. Miranda v. Arizona (1966)
Ernesto Miranda, unemployed drifter, mentally disturbed,
charged with kidnapping & rape of a young girl. He
was identified in a police line-up by the victim.
Miranda was questioned for two hours, and at no time
was he ever informed that he had the right to an
attorney. He signed a confession and above the
confession was a paragraph stating that the suspect
understood his rights and the confession was given
voluntarily.
Found guilty of kidnapping and rape, sentences to 20 to
30 years.
Miranda v. Arizona (1966)
He appealed to the Arizona State Supreme Court, on
the grounds the confession was obtained in violation
of his Fifth Amendment right against selfincrimination. The court upheld the conviction.
The Supreme Court heard the case, along with three
other cases dealing with the same circumstances.
The issue? If police do not tell a suspect of his right to
have an attorney present during questioning, can
statements obtained be admitted into evidence or do
they violate the suspects Fifth Amendment rights?
Miranda v. Arizona (1966)
The Court ruled 5 to 4 to overturn the conviction as
his confession was illegally obtained.
From this point on, suspects must be informed of
their rights prior to questioning. Came to be
known as Miranda rights.
The End