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Keywords

defendantlawyerhearingtrialpleaarraignmentlegal counselguilty plea
defendantlawyerhearingpleaguilty plea

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White v. State of Md., 373 U.S. 59, 83 S.Ct. 1050, 10 L.Ed.2d 193

Facts

The petitioner was arrested on May 27, 1960, and brought before a magistrate for a preliminary hearing on May 31, 1960, which was postponed until August 9, 1960. At that hearing, the petitioner was not represented by a lawyer and entered a guilty plea. His formal arraignment occurred later on September 8, 1960, where he pleaded not guilty and not guilty by reason of insanity. The guilty plea from the preliminary hearing was introduced as evidence during his trial.

Petitioner was arrested on May 27, 1960, and brought before a magistrate on May 31, 1960, for a preliminary hearing. But that hearing was postponed and not actually held until August 9, 1960. At that time petitioner was not yet represented by a lawyer. When arraigned at that preliminary hearing he pleaded guilty.

Issue

Did the lack of counsel during the preliminary hearing, where the defendant entered a guilty plea, violate his rights and warrant the reversal of his conviction?

Did the lack of counsel during the preliminary hearing, where the defendant entered a guilty plea, violate his rights and warrant the reversal of his conviction?

Rule

The court applied the principle that the presence of counsel is necessary at critical stages of criminal proceedings, as established in Hamilton v. Alabama.

We therefore hold that Hamilton v. Alabama governs and that the judgment below must be and is reversed.

Analysis

The court determined that the preliminary hearing was a critical stage of the proceedings, similar to arraignment in Alabama law. The petitioner entered a plea without the benefit of legal counsel, which compromised his ability to understand the implications of his plea and the defenses available to him. The court reiterated that the absence of counsel at such a critical juncture necessitated a reversal of the conviction, regardless of whether prejudice was demonstrated.

For petitioner entered a plea before the magistrate and that plea was taken at a time when he had no counsel.

Conclusion

The Supreme Court reversed the judgment of the lower court, holding that the lack of counsel during the preliminary hearing was a violation of the defendant's rights.

Reversed.

Who won?

The petitioner prevailed in the case because the Supreme Court found that his rights were violated due to the absence of counsel during a critical stage of the proceedings.

The Supreme Court held that the lack of counsel at this stage required the reversal of the conviction, as it was a critical stage of the proceedings.

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