Betts v. Brady
| Betts v. Brady | |
|---|---|
|
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| Argued April 13–14, 1942 Decided June 1, 1942 |
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| Full case name | Betts v. Brady |
| Citations | 316 U.S. 455 (more)
62 S. Ct. 1252; 86 L. Ed. 1595; 1942 U.S. LEXIS 489
|
| Prior history | None |
| Subsequent history | Gideon v. Wainwright |
| Holding | |
| Where a man is tried for robbery, due process of law does not demand that Maryland furnish counsel to an indigent defendant. | |
| Court membership | |
| Case opinions | |
| Majority | Roberts, joined by Stone, Reed, Frankfurter, Byrnes, Jackson |
| Dissent | Black, joined by Douglas, Murphy |
| Laws applied | |
| U.S. Const. amends. VI, XIV | |
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Overruled by
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| Gideon v. Wainwright (1963) | |
Betts v. Brady, 316 U.S. 455 (1942), was a landmark United States Supreme Court case that denied counsel to indigent defendants when prosecuted by a state. It was famously overruled by Gideon v. Wainwright.
In its decision in Johnson v. Zerbst, the Supreme Court had held that defendants in federal courts had a right to counsel guaranteed by the Sixth Amendment. In Powell v. Alabama, the Court had held that state defendants in capital cases were entitled to counsel, even when they could not afford it; however, the right to an attorney in trials in the states was not yet obligatory in all cases as it was in federal courts under Johnson v. Zerbst. In Betts v. Brady, Betts was indicted for robbery and upon his request for counsel, the trial judge refused, forcing Betts to represent himself. He was convicted of robbery, a conviction he eventually appealed to the Supreme Court on the basis that he was being held unlawfully because he had been denied counsel.
He filed writ of habeas corpus at the Circuit Court for Washington County, Maryland claiming he had been denied counsel and then filed a writ to Court of Appeals of Maryland. His petitions were all denied and he finally filed for certiorari to the Supreme Court.
In a six to three decision, the Court found that Betts did not have the right to be appointed counsel with Justice Hugo Black emphatically dissenting. In the majority opinion, Justice Owen Roberts said for the Court,
"The Fourteenth Amendment prohibits the conviction and incarceration of one whose trial is offensive to the common and fundamental ideas of fairness and right, and while want of counsel in a particular case may result in a conviction lacking in such fundamental fairness, we cannot say that the amendment embodies an inexorable command that no trial for any offense, or in any court, can be fairly conducted and justice accorded a defendant who is not represented by counsel."
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