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Gideon V Wainwright - Coggle Diagram
Gideon V Wainwright
Significant Issues in Dissent ( Daniel )
Precedent
Time Frame Between Betts v. Brady and Gideon v. Wainwright
Gideon did not claim the denial of a fair trial
Representation of a lawyer does not guarantee a fair trial
Only 20 years
States
Fearful that the Federal Government/Supreme Court was violating their rights
Court considered applying it only to Federal Government
States became very supportive of the overturning of Betts v. Brady
Overall no dissenting opinions and it was unanimously decided to overturn Betts v. Brady and to allow, in any criminal situation in the court, to be allotted a public defendant
Judges & Majority Ruling ( Daniel )
The Supreme Court ruled unanimously in favor of Gideon,
Guaranteeing the right to legal counsel for criminal defendants
State Courts
Allotted legal counsel for State Prosecution
Federal Courts
Allotted legal counsel for federal prosecution (under Dual Sovereignty Doctrine)
Harlan's concurring opinion stated that "the mere existence of a serious criminal charge in itself constituted special circumstances requiring the services of counsel at trial"
"The average person does not have the knowledge, resources, and skill required to provide an adequate legal defense themselves."
Betts v. Brady
Argued that in cases not relating to the death penalty, no legal counsel should be allowed
Overturned: Twenty-two states filed amicus curiae briefs to support the application of the Sixth Amendment right to counsel to state courts for all offenses
Amicus Curiae: a person or group who is not a party to an action, but has a strong interest in the matter, will petition the court for permission to submit a brief in the action with the intent of influencing the court's decision
Justice Hugo L. Black authored the unanimous opinion in agreement with Gideon, and concurring opinions were written by Justice Harlan, Justice Clark, and Justice Douglas
Comparison to other cases ( Geena )
Miranda V Arizona
5-4 majority delivered by Earl Warren
Required arresting officers to notify arrestees that they
have the right to remain silent
Required arresting officers to notify arrestees that they
have the right to an attorney
reinforced by the fifth amendment
supported by Gideon V Wainwright because
people had to be told they had a right to an attorney even
if they could not afford it
different than Gideon V Wainwright because it is
related to communicating information that validates
certain evidence in court, rather than being actually related
to the physical process of hiring an attorney
Evidence obtained from interrogation could not be used against the defendant unless it is proven that the prosecution gave them the warnings
Chavez v Martinez
Martinez was shot by a policeman after being
stopped on his bike for a narcotics search. He was not
A struggle occurred before being searched, and a tape
later surfaced with Martinez saying he tried to grab the
policeman's gun, but he said this evidence could not
be used against him because he was not read miranda rights
6-3 Decision that Martinez' fifth amendment
rights were not violated by the seargant
5-4 Decision that a violation of substantive due
process should be brought up in the lower courts
for Martinez
similar to Gideon V Wainwright because every individual
is guaranteed a lawyer in court, and Martinez
was not told his right to an attorney or right to remain silent ( set by the Miranda V Arizona case as well ). Both
of these cases are related to due process that all people are
guaranteed by the fifth amendment and equal protection under the law by the 14th amendment
different than Gideon V Wainwright because
this case involves the communication between
a seargant and the arrestee that validates the
use of certain evidence and justifies certain
actions in court, while Gideon V Wainwright involve
the economic standing of the person being tried
and their guarantee of a lawyer regardless of
financial compensation
Essential Questions ( Geena )
To what extent do the U.S Constitution and its
amendments protect against undue government infringement on essential libterties and from invidious discrimination?
Gideon V Wainwright
Invidious Discrimination
Gideon V Wainwright prevented the discrimination of an
individual in court because of financial and socioeconomic status. If someone is unable to afford an attorney, they are guaranteed one by law, which protects people from being at a disadvantage or discrimination.
Infringement on essential liberties
The sixth amendment
“In all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of
Counsel for his defense.”
Because every person has a right to counsel for defense,
the sixth amendment does not differentiate between criminal cases that involve the death penalty or don't. Since everyone is equal under the law and the Constitution has given everyone a right to counsel, then everyone should be given the right to an attorney regardless.
The right to a counsel for defense is a fundamental right to a fair trial.
The fourteenth amendment
Gideon V Wainwright is protected by the
fourteenth amendment, which ensures equal protection
under the law for all US citizens. This guarantees rightful due process and prevents discrimination, which includes every
person's right to an attorney in court. A right to an attorney guarantees every citizen to equal protection from unjust punishment and a proper trial of innocent until proven guilty.
states shall not “deprive any person of life, liberty, or property,
without due process of law.”
How have U.S Supreme Court rulings defined civil liberties and civil rights?
The ruling in Gideon V Wainwright
both protects citizens from government, and
protects people through government ( civil liberties
and rights )
Protection from/through government
The supreme court ruling in Gideon V Wainwright protects citizens from unfair treatment or an unfair trial in court, which could result in an unjust ruling or punishment. Because a person's liberty is at stake during a trial, it ensures fairness and proper due process.
Based on GIdeon V Wainwright, the U.S Supreme Court has
upheld each person's right to a fair trial, to an attorney regardless of the crime or financial standing, equal protection under the law, and guaranteed due process of law
Background/Facts(Danny)
Clarence Earl Gideon arrested on suspicion of burglary
Court rejected his request to be issued a lawyer by the sate on account that he could not afford one
6th amendment defends one's right to a lawyer in order to defend themselves
In 1938 the Supreme Court ruled that the government must pay for a lawyer for a defendant who cannot afford one themselves
The 14th Amendment says that states shall not “deprive any person of life, liberty, or property,
without due process of law.” The Supreme Court used this to support the fact that states should pay for lawyers
Read law in prison and felt this was unconstitutional. He then wrote a petition asking to be seen by the Supreme Court which was accepted
Key Constitutional Issue (Danny)
"Does the Sixth Amendment’s right to counsel in criminal cases extend to defendants in state courts,
even in cases in which the death penalty is not at issue?"
Supreme Court justices looked to the 14th amendment which states that “...nor shall any State deprive any person of life, liberty, or property, without due process of
law....”
Under this Due Process clause, the court ruled unanimously that it is the state's duty to provide a lawyer to protect the rights of citizens
The Supreme Court ruled that even in cases where the death penalty isn't an option, the liberty of citizens is still at risk and there are no "trivial cases."