Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

defendantjurisdictiontrialhabeas corpus
jurisdictionnegligencetrialhabeas corpus

Related Cases

Greyhound Leasing & Financial Corp. v. Norwest Bank of Jamestown, N.W., 854 F.2d 1122
View Case »
People v. Lee, 31 Cal.4th 613, 74 P.3d 176, 3 Cal.Rptr.3d 402, 03 Cal. Daily Op. Serv. 7310, 2003 Daily Journal D.A.R. 9124
View Case »
Greenwald v. Eisinger, Brown, Lewis & Frankel, P.A., 118 So.3d 867, 38 Fla. L. Weekly D1514
View Case »
Matthews v. United States, 13 A.3d 1181
View Case »
Shaw v. State, 243 S.W.3d 647
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Johnson v. Zerbst, 304 U.S. 458, 58 S.Ct. 1019, 82 L.Ed. 1461, 146 A.L.R. 357

Facts

John A. Johnson was arrested along with another individual for passing counterfeit money while they were on leave from the Marine Corps. They were indicted and tried on the same day without the assistance of counsel, as they were unable to afford one. The trial judge did not appoint counsel, and both defendants were convicted and sentenced to four and a half years in prison. Johnson later filed for habeas corpus, claiming he was denied his constitutional right to counsel during the trial.

The record discloses that: Petitioner and one Bridwell were arrested in Charleston, S.C., November 21, 1934, charged with feloniously uttering and passing four counterfeit twenty-dollar Federal Reserve notes and possessing twenty-one such notes.

Issue

Did John A. Johnson's trial violate his Sixth Amendment right to counsel, and can he seek relief through habeas corpus despite the initial denial of his petition?

The Sixth Amendment guarantees that: ‘In all criminal prosecutions, the accused shall enjoy the right * * * to have the Assistance of Counsel for his defence.’

Rule

The Sixth Amendment guarantees the right to counsel in criminal prosecutions, and a conviction without the assistance of counsel, unless intelligently waived, is a jurisdictional bar to a valid conviction.

The constitutional right of an accused to be represented by counsel invokes, of itself, the protection of a trial court, in which the accused—whose life or liberty is at stake—is without counsel.

Analysis

The Supreme Court found that Johnson was not represented by counsel during his trial and that the District Court had not made a determination regarding whether he had intelligently waived his right to counsel. The Court emphasized that the right to counsel is fundamental and that the trial court has a duty to ensure that any waiver of this right is made knowingly and competently. The lack of representation and the circumstances surrounding Johnson's trial raised serious questions about the validity of his conviction.

In this case, petitioner was convicted without enjoying the assistance of counsel.

Conclusion

The Supreme Court reversed the lower court's decision and remanded the case for further proceedings to determine if Johnson had waived his right to counsel. If it is found that he did not waive this right, his conviction would be deemed void.

The cause is reversed and remanded to the District Court for action in harmony with this opinion.

Who won?

John A. Johnson prevailed in the Supreme Court, as the Court recognized the violation of his constitutional rights and ordered further proceedings to address the issue of counsel.

The District Court, holding petitioner could not obtain relief by habeas corpus, said: ‘It is unfortunate, if petitioners lost their right to a new trial through their ignorance or negligence, but such misfortune cannot give this court jurisdiction in a habeas corpus case to review and correct the errors complained of.’

You must be