✸Case Digest✸

GIDEON VS. WAINWRIGHT

372 US 335 (1963) No. 31116
Supreme Court of Florida,
March 18, 1963
Petitioner: Clarence Earl GIDEON, in pro. Per.
Respondents: Louie L. WAINWRIGHT, Director, Division of Corrections.
Ponente: Justice Black (who dissented in Betts) wrote the opinion of the court. Justices Douglas,
Clark, and Harlan each wrote concurring opinions.

FACTS:
Charged in a Florida State Court with a noncapital felony, petitioner appeared without
funds and without counsel and asked the Court to appoint counsel for him, but this was denied
on the ground that the state law permitted appointment of counsel for indigent defendants in
capital cases only. Petitioner conducted his own defense about as well as could be expected of a
layman, but he was convicted and sentenced to imprisonment. Subsequently, he applied to the
State Supreme Court for a writ of habeas corpus, on the ground that his conviction violated his
rights under the Federal Constitution. The State Supreme Court denied all relief.
Gideon next filed a handwritten petition in the Supreme Court of the United States. The
Court agreed to hear the case to resolve the question of whether the right to counsel
guaranteed under the Sixth Amendment of the Constitution applies to defendants in state court.

ISSUES:
A prior decision of the Court’s, Betts v. Brady, 316 U.S. 455 (1942), held that the refusal
to appoint counsel for an indigent defendant charged with a felony in state court did not
necessarily violate the Due Process Clause of the Fourteenth Amendment. The Court granted
Gideon’s petition for a writ of certiorari – that is, agreed to hear Gideon’s case and review the
decision of the lower court – in order to determine whether Betts should be reconsidered.

HELD:
Reversed and remanded. In its opinion, the Court unanimously overruled Betts v. Brady.
Argued: January 15, 1963
Decided: March 18, 1963
Unanimous Decision: Justice Black (who dissented in Betts) wrote the opinion of the court.
Justices Douglas, Clark, and Harlan each wrote concurring opinions
 The Court held that the Sixth Amendment’s guarantee of counsel is a fundamental right
essential to a fair trial and, as such, applies the states through the Due Process Clause of the
Fourteenth Amendment. In overturning Betts, Justice Black stated that “reason and reflection
require us to recognize that in our adversary system of criminal justice, any person haled into
court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is provided
for him.” He further wrote that the “noble ideal” of “fair trials before impartial tribunals in
which ever defendant stands equal before the law . . . cannot be realized if the poor man
charged with crime has to face his accusers without a lawyer to assist him.”

MIRANDA V. ARIZONA
384 U.S 436 (1966) No. 759
Supreme Court of Arizona,
June 13, 1966
Petitioner: Ernesto A. MIRANDA
Respondents: The State of Arizona, GARY K. NELSON, ESQ., Assistant Attorney General, Room 159,
State Capitol Building, Phoenix, Arizona 85007, for Respondent.
Ponente: Chief Justice Warren and joined by Justices Black, Douglas, Brennan, and Fortas.

FACTS:

The Supreme Court’s decision in Miranda v. Arizona addressed four different cases
involving custodial interrogations. In each of these cases, the defendant was questioned by
police officers, detectives, or a prosecuting attorney in a room in which he was cut off from the
outside world. In none of these cases was the defendant given a full and effective warning of his
rights at the outset of the interrogation process. In all the cases, the questioning elicited oral
admissions and, in three of them, signed statements that were admitted at trial.

Miranda v. Arizona: Miranda was arrested at his home and taken in custody to a police station
where he was identified by the complaining witness. He was then interrogated by two police
officers for two hours, which resulted in a signed, written confession. At trial, the oral and
written confessions were presented to the jury. Miranda was found guilty of kidnapping and rape
and was sentenced to 20-30 years imprisonment on each count. On appeal, the Supreme Court
of Arizona held that Miranda’s constitutional rights were not violated in obtaining the
confession.

ISSUES:
Whether “statements obtained from an individual who is subjected to custodial police
interrogation” are admissible against him in a criminal trial and whether “procedures which
assure that the individual is accorded his privilege under the Fifth Amendment to the
Constitution not to be compelled to incriminate himself” are necessary.
HELD:

The Court held that “there can be no doubt that the Fifth Amendment privilege is available
outside of criminal court proceedings and serves to protect persons in all settings in which their
freedom of action is curtailed in any significant way from being compelled to incriminate
themselves.” As such, “the prosecution may not use statements, whether exculpatory or
inculpatory, stemming from custodial interrogation of the defendant unless it demonstrates the
use of procedural safeguards effective to secure the privilege against self-incrimination. By
custodial interrogation, we mean questioning initiated by law enforcement officers after a
person has been taken into custody or otherwise deprived of his freedom of action in any
significant way.”

The Court further held that “without proper safeguards the process of in-custody interrogation
of persons suspected or accused of crime contains inherently compelling pressures which work
to undermine the individual’s will to resist and to compel him to speak where he would
otherwise do so freely.” Therefore, a defendant “must be warned prior to any questioning that
he has the right to remain silent, that anything he says can be used against him in a court of law,
that he has the right to the presence of an attorney, and that if he cannot afford an attorney one
will be appointed for him prior to any questioning if he so desires.”

The Supreme Court reversed the judgment of the Supreme Court of Arizona in Miranda,
reversed the judgment of the New York Court of Appeals in Vignera, reversed the judgment of
the Court of Appeals for the Ninth Circuit in Westover, and affirmed the judgment of the
Supreme Court of California in Stewart.

Argued: Feb. 28, March 1 and 2, 1966

Decided: June 13, 1966

Vote: 5-4

Majority opinion written by Chief Justice Warren and joined by Justices Black, Douglas, Brennan,
and Fortas.

Dissenting opinion written by Justice Harlan and joined by Justices Stewart and White.

Dissenting in part opinion written by Justice Clark.

 MARBURY V. MADISON
5 U.S. 137, 1 Cranch (1803)
U.S Supreme Court,
June 13, 1966
Petitioner: William MARBURY
Respondents: James MADISON
Ponente: Marshall, joined by Paterson, Chase, Washington

FACTS:

Thomas Jefferson defeated John Adams in the presidential election of 1800, which was
decided on February 17, 1801. Before Jefferson took office on March 4, Adams and Congress
passed the Judiciary Act of 1801, which created new district courts, expanded the number of
circuit courts, added more judges to each circuit, gave the President more control over
appointing federal judges, and reduced the number of Supreme Court Justices from six to five.
This law essentially was an attempt by Adams and his political party to frustrate the incoming
opposition, since he used his new power to appoint 16 new circuit judges and 42 new justices of
the peace, a group known as the "Midnight Judges." The incoming appointees were approved by
the Adams Senate, but their appointments were not valid until each of their commissions was
delivered by John Marshall in his capacity as acting Secretary of State.

Justices of the peace were entitled to serve a term of five years. One of the new appointees was
William Marbury, a long-standing supporter of Adams who received the position of justice of the
peace in the District of Columbia. As was the case with a handful of other new appointees,
Marshall failed to deliver Marbury's commission before Adams left office and was succeeded by
Jefferson. With the change in administration, Marshall also left his position as Secretary of State
and was succeeded by James Madison. However, Jefferson ordered acting Secretary of State Levi
Lincoln to cease delivering the commissions, thus preventing the new appointees from taking
their positions. He assumed that they could be considered void, since they were not delivered on
time.

The machinations did not end there, moreover. The Jefferson Congress proceeded to replace the
Judiciary Act of 1801 with a new Judiciary Act of 1802 that essentially restored the initial
Judiciary Act of 1789. It also sought to delay the Supreme Court in hearing the inevitable
challenge to the constitutionality of Jefferson's maneuver by canceling its term in June 1802.
Marbury then filed a writ of mandamus with the Supreme Court, asking it to order the executive
branch to deliver his commission.

ISSUES:

Does the applicant have a vested right in the commission he demands?

OPINIONS:

Majority
• John Marshall (Author)
• William Paterson
• Samuel Chase
• Bushrod Washington

This was a rare case that arrived at the Supreme Court as the court of original jurisdiction rather
than as an appeal from a lower court. Marshall and the other Justices needed to determine not
only whether Marbury had a right to his commission but whether he had a remedy that could be
enforced through the courts. Marshall found that a remedy could be implied because no right
could exist without a remedy. Also, delivering the commission was a purely ministerial function
of the executive branch. By ordering it to comply with its ministerial duties, the Court would not
violate the separation of powers by encroaching on another branch's discretion.

HELD:

Marshall also ruled that a writ of mandamus was the proper way to seek a remedy but grappled
with the question of whether the Supreme Court could issue it. He identified a conflict between
the Judiciary Act of 1789 and the Constitution, each of which provided different parameters for
the Court's original jurisdiction. Marshall rejected Marbury's argument that the Constitution
merely served as a foundation on which Congress could build with later laws, finding that the
Constitution trumped any laws and that Congress did not have the power to modify the
Constitution through regular legislation. In explaining why the Constitution was supreme to all
laws, he noted that the Supremacy Clause places the Constitution before the laws and that
judges must take an oath to uphold the Constitution

As a result, Marshall found that the section of the Judiciary Act of 1789 that purported to give
the Supreme Court original jurisdiction over these matters was invalid because it violated the
Constitution.

[The Supreme Court consisted of only six Justices at this time, so Marshall's four-Justice opinion
was unanimous because two of the Justices recused themselves.]

Recused

 William Cushing (Author)

 Alfred Moore
 ✸Insights✸
Upon reading these Landmark cases, It was only until now that I realized
how important a single case is in changing the course of History (in this
case, the Judicial System of the US). It’s fascinating how a single conflict,
a heated tension between 1.) Madison and Marbury was the impetus for
what we know now as a Judicial Review. It further strengthened the role
of the Judiciary by declaring legislation, as well as executive and
administrative actions, inconsistent with the U.S Constitution
“unconstitutional” and therefore Null and Void. 2.) In the long run, the
effect has been to increase the Court’s power by establishing the rule
that 'it is emphatically the province and duty of the judicial department
to say what the law is.’ 3.) In Gideon vs. Wainwright, it gave birth to a
tremendous contribution to the “due process revolution”, it highlighted
the right of defendants charged with serious offenses to have legal
counsel if they couldn’t afford one. 4.) The Supreme Court’s recognition
in Gideon that “Lawyers in criminal courts are necessities, not luxuries”
and its guarantee of the right to counsel in the state criminal process,
has had a profound impact on the operation and aspirations of American
Criminal Justice system. 5.) The decision of the case also had rippling
impacts on future cases such as the Miranda vs. Arizona: Since Ernesto
Miranda was not informed of his right to remain silent and his resulting
confession should not be used to incriminate him as he was compelled
to be a witness against himself as he was intimidated under the
interrogation of the police. Ultimately, there can be no doubt that the
Fifth Amendment privilege is available outside the criminal court
proceedings and thus, the Miranda Warning was born, which reminds
defendants of their right to remain silent. Anything they say can and will
be used against them in a court of law. Thus, they also have the right to
an attorney. If they cannot afford an attorney, one will be appointed for
them.