Betts v. Brady

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Betts v. Brady
Seal of the United States Supreme Court.svg
Argued April 13–14, 1942
Decided June 1, 1942
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
States do not have to assign free lawyers to poor people who are not charged with capital crimes.
Court membership
Case opinions
Majority Roberts, joined by Stone, Reed, Frankfurter, Byrnes, Jackson
Dissent Black, joined by Douglas, Murphy
Laws applied
Sixth and Fourteenth Amendments
Overruled by
Gideon v. Wainwright (1963)

Betts v. Brady, 316 U.S. 455 (1942), was a landmark case decided by the United States Supreme Court in 1942. The case had to do with "indigent" (poor) people who were on trial for crimes, but could not afford to pay for a lawyer. The Court ruled that a person did not need a lawyer to get a fair trial. They also ruled that the states did not have to pay for free lawyers for poor defendants.

In 1963, the Court reversed its decision in Betts when it decided Gideon v. Wainwright, 372 U.S. 335 (1963).

History[change | change source]

The Sixth Amendment to the United States Constitution says that "In all criminal [trials], the accused shall ... have the assistance of counsel for his defence."[1] ("Counsel" is another word for "lawyer.")

However, in the 1930s, the Supreme Court made a few decisions that decreased the number of United States citizens who had the right to a lawyer.

In 1932, the Court decided a case called Powell v. Alabama, 287 U.S. 45 (1932). They ruled that the states had to assign free lawyers to poor defendants, but only if they were being tried for capital crimes.[2] (Capital crimes are crimes that can be punished with the death penalty.)

Then, in 1938, the Supreme Court ruled in Johnson v. Herbst that in federal courts, any person who was charged with a crime and could not pay for a lawyer had to be assigned a lawyer for free. However, the Court also ruled that the Sixth Amendment applied only to federal courts – not to state courts.[3]

This meant that if a person was charged with a crime in a state court, and he could not afford a lawyer, he would have to defend himself in court.[3]

Background of the case[change | change source]

In 1941, Betts was indicted (formally charged) with robbery by a court in Maryland. Betts could not pay for a lawyer. He asked the court to assign him a free lawyer. The judge refused. He said the court only appointed free lawyers to people charged with rape or murder.[4]

Betts had to defend himself, without the help of a lawyer. He argued that he had been in a different place at the time of the robbery. He called witnesses who said this was true. However, the judge did not believe Betts. He sentenced Betts to eight years in prison.[4]

Appeals[change | change source]

Betts filed a writ of habeas corpus with a Maryland appeals court. A writ of habeas corpus asks to be set free from unfair imprisonment. Betts argued that his imprisonment was unfair because he had not been given a lawyer. His petition was denied.[5]

Next Betts filed a writ of habeas corpus to the Court of Appeals of Maryland, the most powerful court in Maryland. It also denied his petition.[5]

Finally, Betts filed a request with the Supreme Court of the United States, asking them to hear his case. The Court agreed.

Legal issues[change | change source]

The Betts case brought up some important legal issues for the Court to decide.

The Sixth Amendment to the United States Constitution says that "In all criminal [trials], the accused shall ... have the assistance of counsel for his defence."[6]

Also, the Fourteenth Amendment says that no state can take away any person's "life, liberty, or property, without due process of law; nor deny to any person ... the equal protection of the laws."[7]

The Court had already decided that the right to have a lawyer applied to all people in federal criminal trials; people being tried by the states for rape or murder; and anyone who could pay for a lawyer. Now they needed to decide whether poor people had the right to have lawyers too, even if they could not pay for them.

[I]n the great majority of the States, it has been the considered judgment of the people, their representatives, and their courts that appointment of counsel is not a fundamental right, [and is not] essential to a fair trial.

– Justice Roberts, giving the Court's majority opinion in Betts[8]

They also needed to decide these questions:[4]

  • If a poor person did not have a lawyer, could they get a fair trial?
  • Without a lawyer, would a poor person be getting the "due process" that the Constitution required?
  • If poor people could not get lawyers, would they be getting the "equal protection of the laws?"

Decision[change | change source]

On June 1, 1942, the Supreme Court voted 6–3 against Betts. They ruled that his conviction was fair.[5]

The Court ruled that having a lawyer was not a basic right. Usually, a defendant did not need a lawyer to get a fair trial, the Court said.[5]

In their decision, the Court did rule that there were special cases where a court should assign a lawyer.[9] In these special cases, not having a lawyer would make it difficult for a defendant to get a fair trial. In each case, the judge was supposed to talk to the defendant to figure out whether any of these "special circumstances" existed. For example, was the defendant mentally able to defend himself? Did he have enough education? Did he understand what happens during a trial?[9]

Importance[change | change source]

For 21 years, Betts set a precedent that allowed individual courts and judges to decide whether poor people would be given lawyers or not.

Finally, in 1963, the Supreme Court decided a case called Gideon v. Wainwright, 372 U.S. 335 (1963). In the Gideon decision, the Court admitted that it made the wrong decision in Betts. A lawyer is needed for a fair trial.[10]

Related pages[change | change source]

References[change | change source]

  1. "The Constitution of the United States: A Transcription". The Charters of Freedom. Washington, D.C.: United States National Archives and Records Administration. Retrieved March 13, 2016. 
  2. Powell v. Alabama, 287 U.S. 45 (1932).
  3. 3.0 3.1 Johnson v. Herbst, 304 U.S. 458 (1938).
  4. 4.0 4.1 4.2 "Betts v. Brady, 1942". Textbook Resources: Supreme Court Cases. Pearson Prentice Hall. Retrieved March 29, 2016. 
  5. 5.0 5.1 5.2 5.3 Betts v. Brady, 316 U.S. 455 (1942).
  6. "The Constitution of the United States: A Transcription". The Charters of Freedom. Washington, D.C.: United States National Archives and Records Administration. Retrieved March 29, 2016. 
  7. "Constitution of the United States: Amendments 11-27". Charters of Freedom. United States National Archives and Records Administration. Retrieved March 27, 2016. 
  8. Betts v. Brady, 316 U.S. 455 (1942) at 471.
  9. 9.0 9.1 Jacob, Bruce R.. "The Gideon Trials". Iowa Law Review 99: 2059-2101. http://ilr.law.uiowa.edu/files/ilr.law.uiowa.edu/files/A10_Jacob.pdf. Retrieved March 29, 2016.
  10. Gideon v. Wainwright, 372 U.S. 335 (1963).