Gideon v. Wainwright · ¶32

The principles declared in Powell and in Betts, however, have had a troubled journey throughout the years that have followed first the one case and then the other. Even by the time of the Betts decision, dictum in at least one of the Court’s opinions had indicated that there was an absolute right to the services of counsel in the trial of state capital cases. Such dicta continued to appear in subsequent decisions, and any lingering doubts were finally eliminated by the holding of Hamilton v. Alabama, 368 U. S. 52.

U. S. Reports, bound volume
U. S. Reports, volume 372, at 335 (Library of Congress) · transcription: Caselaw Access Project
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