Case Name and Citation: Powell v. State of Alabama 287 U.S. 45 (1932).
- Judicial history:
Nine African Americans, whom attorneys described as ignorant and unintelligent were accused of raping two white females, who travelled on a freight train from Chattanooga to Alabama. Officials immediately started the legal proceedings (Cretacci, 2008). The three trials took one day, and nine men received a death sentence. Although the Alabama legislation required to provide a counsel in such cases, no attorneys consulted with defendants and did little more than just to appear and represent the clients at the trial. The nine accused men appealed from the Supreme Court’s order that confirmed conviction and death sentence on charges of rape.
African American youth travelled on the train to Alabama. They started to fight with white men and threw them off the train. Subsequently, all African-Americans were requested to get off the train. Two white women, who travelled on the same train, testified that six men had raped them. The public met accused youth with hostility, and later they the men taken into custody. The judge appointed the bar for arraignment. Since the accused men were illiterate, they were tried separately. Each trial lasted a day. The men were convicted and sentenced to death.
Whether failure to provide attorneys to the accused individuals in order to properly organize the defense and failure to allow the defendants to confer with their attorney, violated the due process guarantee?
If the defendants cannot employ counsels and organize own defense, the court, whether requested or not, should assign counsels for them since it is an essential requisite of due process. Despite assignments and under any circumstances, no one is exempt from his/her duties, and no one should interfere with the provision of effective assistance when preparing for the trial. According to the Alabama Constitution, the defendants should have the right to enjoy the counsel’s assistance in all criminal prosecutions. Moreover, according to the state statute, the court should provide the accused men with the counsels in the capital cases if they cannot employ them by themselves (Powell v. Alabama, n.d.).
The court quashed the conviction and held that the accused men were denied their right to have an attorney during the trial thus violating the 14th Amendment. The court also pointed to the fact that defendants did not get the proper legal aid since the arraignment until the beginning of the trial. Moreover, defendants’ young age, circumstances, illiteracy, and public hostility made the necessity of an attorney vitally important. The failure of the trial court to ensure an immediate appointment of attorney and the failure to provide the accused men with a reasonable opportunity to get the professional assistance were described as a clear rejection of due process.
Due process points to the fact that all accused individuals should have adequate access to the lawyer and sufficient time to prepare the defense. The Court concluded that the trial denied due process since no reasonable time and opportunity were given to the criminal defendants to secure an attorney in their defense. Although the judge Sutherland did not emphasize the court’s holding regarding the guarantee to have a counsel according to the 6th Amendment, he repeatedly implicated it. Many legislators described the case as an early example of how the national constitution protects the criminal justice field. The due process clause of the 14th Amendment declares that every state should inform ignorant defendants charged with a criminal act that they have a right to get a professional help of the counsel. The court should appoint counsels in the case if accused men cannot hire attorneys and ensure sufficient time to prepare for the trial. The Supreme Court pointed to violation of due process in the Powell v. Alabama case.