Douglas v. California
| Bennie Will Meyes and William Douglas | |
|---|---|
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| Argued April 7, 1962 Reargued January 16, 1963 Decided March 18, 1963 |
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| Full case name | Douglas et al. v. State of California |
| Citations | 372 U.S. 353 (more) |
| Prior history | Appeal from the District Court of Appeal of California, Second Appellate District |
| Holding | |
| Denying defense counsel during appellate review is unconstitutional | |
| Court membership | |
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| Case opinions | |
| Majority | Douglas, joined by Warren, Black, Brennan, White, Goldberg |
| Dissent | Clark |
| Dissent | Harlan, joined by Stewart |
| Laws applied | |
| Fourteenth Amendment to the United States Constitution | |
Douglas v. California, 372 U.S. 353 (1963), was a case before the United States Supreme Court.
Two defendants were tried and convicted in a California state court on felony charges including robbery, assault with a deadly weapon, and assault with intent to commit murder.
A single public defender had been appointed to represent them on these three charges. The attorney's motion for continuance at the beginning of trial was denied, although he stated that he was not as prepared as he should have been. Thereafter the defendants dismissed the defender and renewed motions for separate counsel and for a continuance. These motions were also denied. The defendants were convicted and subsequently filed appeals.
Exercising their only right to appeal as of right, they appealed to an intermediate Court of Appeals (District court of appeal of California, second appellate district), and, being indigent, applied to it for appointment of counsel to assist them on appeal. In accordance with a state rule of criminal procedure, that Court made an ex parte examination of the record, determined that appointment of counsel for petitioners would not be "of advantage to the defendant or helpful to the appellate court" and denied appointment of counsel. Their appeal was heard without assistance of counsel and their convictions were affirmed. The District Court of Appeal affirmed their convictions after denying their request for appointment of counsel under a California rule of criminal procedure authorizing such denial where after an independent investigation of the record the appellate court determines that appointment of counsel would be helpful to neither the defendant nor the court. (187 Cal App 2d 802, 10 Cal Rptr 188.)
The California Supreme Court denied their petitions for a discretionary review/hearing. (187 Cal App 2d 813, 10 Cal Rptr 214.)
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