Indigent Criminal Defense Research Guide

One of the most important cases, and certainly the most infamous, of the pre-Gideon era was Powell v. Alabama. Powell involved the wrongful convictions of nine young African-American men accused of raping two white women on a freight train. The defendants could not afford representation, and only inadequate representation was provided by the state. Eight of the defendants were sentenced to death; the ninth to life in prison. After the first stage of trials, the Supreme Court reversed the convictions, holding that counsel must be provided in capital cases.

Collection of documents from committee, formed by the NAACP to assist the Scottsboro defendants.

A contemporaneous account of the Scottsboro case written by the ACLU.

The case Betts v. Brady specifically held that indigent state defendants did not have the right to court-provided counsel. The case would be overruled by Gideon.

Verified the right to court-appointed counsel in federal, but not state, prosecutions.

Held that in a capital case, the right to counsel attaches at the time of arraignment.