"[1] Between midnight and 8:00 a.m. on June 3, 1961, a burglary occurred at the Bay Harbor Pool Room in Panama City, Florida.
An unknown person broke a door, smashed a cigarette machine and a record player, and stole money from a cash register.
Later that day, a witness reported that he had seen Clarence Earl Gideon in the poolroom at around 5:30 that morning, leaving with a wine bottle, a Coca-Cola, and some change in his pockets.
Based on this accusation alone, the police arrested Gideon and charged him with breaking and entering with intent to commit petty larceny.
Under the laws of the State of Florida, the only time the court can appoint counsel to represent a defendant is when that person is charged with a capital offense.
[7] Under the existing framework, a magistrate in a preliminary hearing determined whether there were "special circumstances" in the case meriting that the defendant receive counsel.
For example, whether a witness's statement should be barred because it was hearsay is an extremely complicated issue that no layman could readily confront, and such a situation arises only during a trial.
As a second point, Fortas presented during oral argument that it was widely accepted in the legal community that the first thing any reputable lawyer does when accused of a crime is hire an attorney.
Betts v. Brady (1942) had earlier held that, unless certain circumstances were present, such as illiteracy or low intelligence of the defendant, or an especially complicated case, there was no need for a court-appointed attorney in state court criminal proceedings.
Gideon overruled Betts, holding that the assistance of counsel, if desired by a defendant who could not afford to hire counsel, was a fundamental right under the United States Constitution, binding on the states, and essential for a fair trial and due process of law regardless of the circumstances of the case.
This noble ideal cannot be realized if the poor man charged with crime has to face his accusers without a lawyer to assist him.
[6] 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.
Gideon v. Wainwright was one of a series of Supreme Court decisions that confirmed the right of defendants in criminal proceedings, upon request, to have counsel appointed both during the trial and on appeal.
In the subsequent cases Massiah v. United States, 377 U.S. 201 (1964), and Miranda v. Arizona 384 U.S. 436 (1966), the Supreme Court further extended the rule to apply during police interrogation.
The decision did not directly result in Gideon being freed; instead, he received a new trial with the appointment of defense counsel at the government's expense.
In his opening and closing statements, Turner suggested that Cook likely had been a lookout for a group of young men who broke into the poolroom to steal beer and then grabbed the coins while they were there.
[11] It was inscribed with a quote from a letter Gideon wrote to Abe Fortas, the attorney appointed to represent him in the Supreme Court: "Each era finds an improvement in law for the benefit of mankind.
[17] Additionally, an influential 1997 article by a federal district court judge helped revitalize the conversation about the need and justification for a right to counsel in civil cases.
[20] Proponents of the movement also argue that a right to counsel "saves federal and state government money by helping to avoid the negative externalities caused by litigants wrongly losing their civil cases (such as increased use of shelters, emergency medical care, foster care, police, and public benefits), and increases the public's faith and investment in the judicial process".
For example, in 2006, the American Bar Association adopted Resolution 112A, urging jurisdictions to provide legal counsel "as a matter of right at public expense to low-income persons in those categories of adversarial proceedings where basic human needs are at stake".
Aid through lawyer substitutes has become more prevalent, involving non-lawyer professionals who can assist clients in legal matters without the supervision of a certified attorney.
Doughty v. Maxwell demonstrates the differences between how states and the federal government address standards for waiver of the right to counsel.
[24] State laws on the subject are often less strict, making it easier for prosecutors to obtain a defendant's waiver of the right to trial.