United States v. Gouveia, 467 U.S. 180 (1984), was a case in which the United States Supreme Court held that prisoners in administrative segregation pending the investigation of crimes committed within the prison had no Sixth Amendment entitlement to counsel prior to the initiation of adversary judicial proceedings against them.

[1] In an opinion written by Justice William Rehnquist, the Court stated that the right to counsel may extend to "'critical' pretrial proceedings" that are adversarial in nature, but the Sixth Amendment right to counsel "attaches at the initiation of adversary judicial criminal proceedings".

[2]

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