Powell v. Alabama
| Powell v. Alabama | |
|---|---|
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| Argued October 10, 1932 Decided November 7, 1932 |
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| Full case name | Ozie Powell, Willie Roberson, Andy Wright, and Olen Montgomery v. State of Alabama |
| Citations | 287 U.S. 45 (more)
53 S. Ct. 55; 77 L. Ed. 158; 1932 U.S. LEXIS 5; 84 A.L.R. 527
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| Prior history | Defendants convicted, Jackson County, Alabama Circuit Court, April 8, 1931; affirmed in part, 141 So. 201 (Ala. 1932); rehearing denied, Supreme Court of Alabama, April 9, 1932; cert. granted, 286 U.S. 540 (1932) |
| Subsequent history | Supreme Court of Alabama reversed |
| Holding | |
| Under the Due Process Clause of the 14th Amendment, a state must inform illiterate, defendants charged with a capital crime that they have a right to be represented by counsel and must appoint counsel for defendants who cannot afford to hire a lawyer and give counsel adequate time to prepare for trial. | |
| Court membership | |
| Case opinions | |
| Majority | Sutherland, joined by Hughes, Van Devanter, Brandeis, Stone, Roberts, Cardozo |
| Dissent | Butler, joined by McReynolds |
| Laws applied | |
| The Fourteenth Amendment Due Process Clause | |
In Powell v. Alabama, 287 U.S. 45 (1932) the United States Supreme Court reversed the convictions of nine young black men for allegedly raping two white women on a freight train near Scottsboro, Alabama. The majority of the Court reasoned that the right to retain and be represented by a lawyer was fundamental to a fair trial and that at least in some circumstances, the trial judge must inform a defendant of this right. In addition, if the defendant cannot afford a lawyer, the court must appoint one sufficiently far in advance of trial to permit the lawyer to prepare adequately for the trial.
Powell was the first time the Court had reversed a state criminal conviction for a violation of a criminal procedural provision of the United States Bill of Rights. In effect, it held that the Fourteenth Amendment Due Process Clause included at least part of the right to counsel referred to in the Sixth Amendment, making that much of the Bill of Rights binding on the states as well as the federal government. Before Powell, the Court had reversed state criminal convictions only for racial discrimination in jury selection — a practice that violated the Equal Protection Clause of the Fourteenth Amendment.
In March 1931, nine black men—Charlie Weems, Ozie Powell, Clarence Norris, Olen Montgomery, Willie Roberson, Haywood Patterson, Andrew (Andy) Wright, Leroy (Roy) Wright and Eugene Williams, later known as the Scottsboro Boys—were accused of raping two young white women, Ruby Bates and Victoria Price.
The group of young black men were on a freight train with seven white men and two women. A fight broke out, and all but one of the white men were thrown from the train. The women accused the black men of rape, although one woman later retracted her claim. All the defendants, except for 13-year-old Roy Wright, were sentenced to death in a series of three one-day trials. The defendants, who were under military guard to protect them from any mob violence, were not told they could hire lawyers or even contact their families. They had no access to a lawyer until shortly before trial, leaving little or no time to plan the defense. They appealed their convictions on the grounds that the group was not provided adequate legal counsel. The Alabama Supreme Court ruled 7-2 that the trial was fair. Chief Justice Anderson wrote a strongly worded dissenting opinion. The defendants appealed the Alabama Supreme Court's ruling to the U.S. Supreme Court.
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