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 self-incrimination. 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.