Landmark Supreme Court Cases: Powell v. Alabama (1932)
Powell v. Alabama (1932) is the 58th landmark Supreme Court case, the seventh 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
- Science & Technology
- 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.
Powell v. Alabama (1932)
In March 1931, nine black men described as, “young, ignorant, and illiterate”—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 of young black men were on a freight train with seven white men and two women. A fight broke out, and all of the white men were thrown from the train. The women accused the black men of rape, although one woman later retracted her claim.
All the defendants, except for 13-year-old Roy Wright, were sentenced to death in a series of three one-day trials. The defendants, who were under military guard to protect them from any mob violence, were not told they could hire lawyers or even contact their families though Alabama law required the appointment of counsel in capital cases.
The defendants had no access to a lawyer until shortly before trial, leaving little or no time to plan the defense. The attorneys did not consult with their clients and had done little more than appear to represent them at the trial.
The defendants appealed their convictions on the grounds that the group was not provided adequate legal counsel. The Alabama Supreme Court ruled 7-2 that the trial was fair. The defendants appealed the Alabama Supreme Court’s ruling to the U.S. Supreme Court.
Powell Legal Questions and Answers
Q: Did the trials violate the Due Process Clause of the 14th amendment?
A: Yes. The trial court denied defendants due process by failing to provide reasonable opportunity to secure counsel in their defense.
7-2 ruling under the Due Process Clause of the 14th Amendment, a state must inform illiterate defendants charged with a capital crime that they have a right to be represented by counsel and must appoint counsel for defendants who cannot afford to hire a lawyer and give counsel adequate time to prepare for trial. The right to retain and be represented by a lawyer was fundamental to a fair trial and that at least in some circumstances, the trial judge must inform a defendant of this right. Court reversed the convictions of nine young black men for allegedly raping two white women on a freight train near Scottsboro, Alabama.
The defendants, known as the Scottsboro Boys, were the first to have the Supreme Court reverse a state criminal conviction for a violation of a criminal procedural provision of the Bill of Rights incorporating the Sixth Amendment right to counsel on the states as well as the federal government. This case was an early example of national constitutional protection in the field of criminal justice.
Whether Powell v. Alabama applied to non-capital cases sparked heated debate. Betts v. Brady (1942) initially decided that, unless there were special circumstances such as illiteracy or a complicated trial, there was no need for a court-appointed attorney. That decision was ultimately overturned in Gideon v. Wainwright (1963), which established the right of an indigent felony defendant to be provided a trial attorney. Later Supreme Court cases have considered how early in the criminal process this right attaches, whether it applies to misdemeanors, and whether it applies to appeals from convictions.
Next Criminal Justice Case: Palko v. Connecticut (1937)
Previous Criminal Justice Case: Olmstead v. U.S. (1928)
Previous Case: Near v. Minnesota (1931)