Powell v. Alabama

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Powell v. Alabama
Seal of the United States Supreme Court.svg
Argued October 10, 1932
Decided November 7, 1932
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
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
Defendants' conviction was unconstitutional because they were denied the assistance of counsel from the time of their arraignment until the beginning of their trial, in violation of the 14th Amendment's Due Process Clause. Under the Due Process Clause of the 14th Amendment, counsel must be guaranteed to anyone facing the possibility of a death sentence, whether in state or federal courts.
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

Powell v. Alabama 287 U.S. 45 (1932) was a United States Supreme Court decision which determined that in a capital trial, the defendant must be given access to counsel upon his or her own request as part of due process.[1]

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.[2] The only prior reversals of state criminal convictions had held that racial segregation in jury selection violated the Equal Protection Clause.[2]

Background of the case[edit]

The case stems from events that occurred 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 was traveling in a freight train with seven white males and two white females. A fight broke out and all of the white males, except for one, were thrown from the train. The women accused the black men of rape, although one woman later retracted her claim. All of the defendants, except for Roy Wright, were sentenced to death in a series of one-day trials. The defendants were only given access to their lawyers immediately prior to the trial, leaving little or no time to plan the defense. The ruling was appealed on the grounds that the group was not provided adequate legal counsel. The Alabama Supreme Court ruled 6-1 that the trial was fair (the strongly dissenting opinion was from Chief Justice Anderson). This ruling was then appealed to the U.S. Supreme Court.

The court's decision[edit]

The majority opinion reversed and remanded the decisions of the Alabama Supreme Court, holding that due process had been violated. The ruling was based on three main arguments: "(1) They were not given a fair, impartial and deliberate trial; (2) They were denied the right of counsel, with the accustomed incidents of consultation and opportunity for trial; and (3) They were tried before juries from which qualified members of their own race were systematically excluded."

Subsequent jurisprudence[edit]

Whether or not the Powell v. Alabama decision applied to non-capital cases sparked heated debate. Betts v. Brady initially decided that, unless there were special circumstances like illiteracy, stupidity or being in an especially complicated trial, there was no need for a court-appointed attorney. That decision was ultimately overturned in Gideon v. Wainwright, which established the right to be provided an attorney in all felony cases."

See also[edit]

Notes[edit]

  1. ^ "ACLU History: Scottsboro Boys". American Civil Liberties Union. 
  2. ^ a b Michael J. Klarman, The Racial Origins of Modern Criminal Procedure, 99 Mich. L. Rev. 48 (2000).

External links[edit]

Works related to Powell v. Alabama at Wikisource