ABSTRACT
In Alabama v. Shelton, 535 US 654, a divided US Supreme Court significantly expanded the Sixth Amendment right to counsel. The ruling in Shelton was a further attempt by the Court to define the parameters of the Sixth Amendment right to counsel. LeReed Shelton represented himself in an Alabama criminal trial. The court warned Shelton several times about the difficulties associated with self-representation, but at no time did the court offer Shelton state-appointed counsel. Shelton was convicted of a misdemeanor and sentenced to thirty days in jail. The dissenting justices believed the Court's ruling placed an undue burden on the states. Several states were affected by the Court's ruling in Shelton. The Court found that a suspended sentence that may ultimately result in imprisonment cannot be imposed upon a defendant if the state did not provide the defendant with counsel at trial.
