SCOTUS Comparison: Betts v. Brady and Gideon v. Wainwright

In 1941, Smith Betts was arrested for robbery in the state of Maryland. Unable to afford a lawyer, he was denied a public defender by a judge and forced to represent himself. He was found guilty and given an eight-year sentence. In the ensuing case, Betts v. Brady (1942), the Supreme Court ruled against Mr. Betts, who claimed his constitutional right to a fair trial was denied. In a 6-3 decision, the Court held that the right to counsel applied to only criminal cases in federal courts and that he did not have a right to counsel in a state court, except in death penalty cases. Justice Black, in his dissenting opinion, reasoned, “This case can be determined by a resolution of a narrower question: whether, in view of the nature of the offense and the circumstances of his trial and conviction, this petitioner was denied the procedural protection which is his right under the federal Constitution. I think he was.”