Landmark Supreme Court Case: Betts v. Brady (1942)
Betts v. Brady (1942) is the 81st landmark Supreme Court case, ninth in the Criminal Rights module, featured in the KTB Prep American Government and Civics series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Betts v. Brady (1942)
In Powell v. Alabama (1932), the Court had held that state defendants in capital cases were entitled to counsel, even when they could not afford it; however, the right to an attorney in trials in the states was not yet obligatory in all cases. Betts was indicted for robbery in Maryland. He was unable to afford counsel and requested one be appointed for him. The judge in the case denied the request, and Betts subsequently pled not guilty. He would go on to be convicted of robbery.
Betts filed writ of habeas corpus at the Circuit Court for Washington County, Maryland claiming he had been denied counsel and then filed a petition for writ of certiorari to the Court of Appeals of Maryland (the Maryland ultimate appellate court). His petitions were all denied and he finally filed for certiorari to the Supreme Court.
Q: Does denying a request for counsel for an indigent defendant violate the Constitution?
A: Criminal defendants who cannot afford a lawyer do not have a right to a state-appointed attorney in their defense
6-3 holding where a man is tried for robbery, due process of law does not demand that Maryland furnish counsel to an indigent defendant. Betts did not have a constitutional right to counsel.
While the Fourteenth Amendment prohibits an unfair trial, the amendment does not embody “an inexorable command that no trial for any offense, or in any court, can be fairly conducted and justice accorded a defendant who is not represented by counsel.” The majority opinion concluded that indigent defendants need only be provided with a lawyer under special circumstances.
Justice Black dissented saying that:
- The denial of counsel based on financial stability makes it so that those in poverty have an increased chance of conviction, which is not equal protection of the laws under the Fourteenth Amendment.
- Had the proceedings of Betts’s case been held in federal court, his petition for counsel to be appointed to him would have been accepted and counsel would have been appointed. Because this right was guaranteed in federal courts, the Fourteenth Amendment should make the right obligatory upon the states
- A man of even average intelligence could not possibly be expected to represent himself without any training in such matters as the law.
This case was famously overruled by Gideon v. Wainwright (1963).
Next Criminal Rights Case: Adamson v. California (1947)
Previous Criminal Rights Case: Palko v. Connecticut (1937)
Next Case: Ex Parte Quirin (1942)
Previous Case: U.S. v. Darby Lumber (1941)