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Facts of the Case

Provided by Oyez

Betts was indicted for robbery in Maryland. He was unable to afford counsel and requested one be appointed for him. The judge in the case denied the request, and Betts subsequently pled not guilty. He was convicted of robbery, which he eventually appealed to the Supreme Court. He argued he was wrongfully denied his right to counsel.


Questions

  1. Does denying a request for counsel for an indigent defendant violate the Constitution?

Conclusions

  1. In an opinion authored by Justice Owen Roberts, the majority ruled Betts did not have a constitutional right to counsel. The Court reasoned that while the Fourteenth Amendment prohibits an unfair trial, the amendment does not embody “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.” The majority opinion concluded that indigent defendants need only be provided with a lawyer under special circumstances.

    Justice Black dissented, arguing that denial of counsel based on financial stability makes it so that those in poverty have an increased chance of conviction, which violates the Fourteenth Amendment Equal Protection Clause. 

    This decision was overruled in 1963 in Gideon v. Wainwright