Argersinger v. Hamlin
32 L. Ed. 2d 530 · Supreme Court of the United States · 1972
Facts
An indigent petitioner in Florida was charged with carrying a concealed weapon, an offense punishable by up to six months imprisonment or a $1,000 fine, or both. He was tried before a judge without legal representation, as he was unable to afford counsel. The petitioner was subsequently sentenced to 90 days in jail for this offense. He argued that without counsel, he could not properly present his defense.
Procedural history
The petitioner brought a habeas corpus action in the Florida Supreme Court, alleging he was deprived of his right to counsel. The Florida Supreme Court ruled that the right to court-appointed counsel extends only to trials for non-petty offenses punishable by more than six months imprisonment. The U.S. Supreme Court granted certiorari to review this decision.
Issue
Does the Sixth Amendment right to counsel, made applicable to the states by the Fourteenth Amendment, require the appointment of counsel for indigent defendants in misdemeanor cases where actual imprisonment is imposed?
Holding
Yes. The Court held that absent a knowing and intelligent waiver, no person may be imprisoned for any offense, whether classified as petty, misdemeanor, or felony, unless they were represented by counsel at trial.
Rule
The Sixth Amendment guarantees the right to counsel in all criminal prosecutions where the accused faces actual imprisonment, regardless of the offense's classification (petty, misdemeanor, or felony). This rule is based on the principle that the assistance of counsel is a requisite for a fair trial, as legal and constitutional questions can be complex even in cases leading to brief imprisonment. The Court reasoned that the prospect of losing liberty, however short the time, is never trivial and necessitates the "guiding hand of counsel."
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