Powell v. Alabama
Encyclopedia
Powell v. Alabama 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
.
s — 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.
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.
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."
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
trial
Trial court
A trial court or court of first instance is a court in which trials take place. Such courts are said to have original jurisdiction.- In the United States :...
, the defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
must be given access to counsel upon his or her own request as part of due process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
.
Background of the case
The case stems from events that occurred in March, 1931. Nine African AmericanAfrican American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
s — Charlie Weems, Ozie Powell, Clarence Norris, Olen Montgomery, Willie Roberson, Haywood Patterson
Haywood Patterson
Haywood Patterson was one of the Scottsboro Boys . He was accused of raping Victoria Price and Ruby Bates...
, Andrew (Andy) Wright, Leroy (Roy) Wright and Eugene Williams, later known as the Scottsboro Boys
Scottsboro Boys
The Scottsboro Boys were nine black teenage boys accused of rape in Alabama in 1931. The landmark set of legal cases from this incident dealt with racism and the right to a fair trial...
, 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
Alabama Supreme Court
The Supreme Court of Alabama is the highest court in the state of Alabama. The court consists of an elected Chief Justice and eight elected Associate Justices. Each justice is elected in partisan elections for staggered six year terms. The Governor of Alabama may fill vacancies when they occur...
ruled 6-1 that the trial was fair (the strongly dissenting opinion
Dissenting opinion
A dissenting opinion is an opinion in a legal case written by one or more judges expressing disagreement with the majority opinion of the court which gives rise to its judgment....
was from Chief Justice
Chief Justice
The Chief Justice in many countries is the name for the presiding member of a Supreme Court in Commonwealth or other countries with an Anglo-Saxon justice system based on English common law, such as the Supreme Court of Canada, the Constitutional Court of South Africa, the Court of Final Appeal of...
Anderson). This ruling was then appealed to the U.S. Supreme Court.
The court's decision
The majority opinion reversed and remanded the decisions of the Alabama Supreme Court, holding that due processDue process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
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
Whether or not the Powell v. Alabama decision applied to non-capitalCapital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
cases sparked heated debate. Betts v. Brady
Betts v. Brady
Betts v. Brady, 316 U.S. 455 , was a landmark United States Supreme Court case that denied counsel to indigent defendants when prosecuted by a state. It was famously overruled by Gideon v. Wainwright.- Background :...
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
Public defender
The term public defender is primarily used to refer to a criminal defense lawyer appointed to represent people charged with a crime but who cannot afford to hire an attorney in the United States and Brazil. The term is also applied to some ombudsman offices, for example in Jamaica, and is one way...
. That decision was ultimately overturned in Gideon v. Wainwright
Gideon v. Wainwright
Gideon v. Wainwright, , is a landmark case in United States Supreme Court history. In the case, the Supreme Court unanimously ruled that state courts are required under the Sixth Amendment of the Constitution to provide counsel in criminal cases for defendants who are unable to afford their own...
, which established the right to be provided an attorney in all felony cases."
See also
- Scottsboro BoysScottsboro BoysThe Scottsboro Boys were nine black teenage boys accused of rape in Alabama in 1931. The landmark set of legal cases from this incident dealt with racism and the right to a fair trial...
- List of United States Supreme Court cases, volume 287
- continuanceContinuanceIn American procedural law, a continuance is the postponement of a hearing, trial, or other scheduled court proceeding at the request of either or both parties in the dispute, or by the judge sua sponte. In response to delays in bringing cases to trial, some states have adopted "fast-track" rules...
External links
- of Powell v. Alabama
- Powell v. Alabama, 287 U.S. 45 (1932) (opinion full text).