Monday, November 4, 2013

Powell v. Alabama case brief

Powell v. Alabama case brief summary
287 U.S. 45 (1932)

CASE SYNOPSIS
Defendants appealed from the order of the Supreme Court of Alabama that affirmed their convictions and death sentences on charges of rape.

CASE FACTS
Defendants pled not guilty in state court to charges of rape after an incident that took place on a freight train. Although it was recited that defendants were represented by counsel upon arraignment, no counsel had been employed until the day of the trial. Prior to that time, the trial judge had appointed all members of the bar for the limited purpose of arraigning defendants. Defendants were ultimately found guilty and sentenced to death. The trial court overruled defendants' motions for new trials, and their convictions were affirmed by the state supreme court.

DISCUSSION
  • The court reversed the convictions and remanded, holding that defendants were denied their right to counsel in violation of the Fourteenth Amendment. 
  • The court held that defendants did not have the aid of counsel in any real sense from the time of their arraignment until the beginning of trial. 
  • The court noted that defendants' illiteracy, youth, and the circumstances of public hostility made the necessity of counsel so imperative that the trial court's failure to make an effective appointment of counsel and the failure to give defendants a reasonable opportunity to secure counsel was a clear denial of due process.

CONCLUSION

The court reversed and remanded the order of the state supreme court, which upheld defendants' convictions and death sentences for rape because defendants were denied counsel from the time of their arraignment until the beginning of their trial in violation of their rights to due process under the Fourteenth Amendment.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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