ABSTRACT
In Johnson v. Zerbst, 304 US 458, the Court maintained that persons accused in federal courts of felonious criminal acts, including noncapital offenses, had a basic right to legal representation regardless of their economic status. For the accused without funds, the story was much different, since there was no language in the amendment that obligated government to provide counsel to the indigent accused. Unless the state constitution or the state legislature specifically provided for indigents to receive court-appointed counsel, the traditional practice required defendants to defend themselves. The right to counsel also applies to preliminary hearings, as held in Coleman v. Alabama, 399 US 1, and to police lineups, the ruling in United States v. Wade,388 US 218. Most states provide persons convicted of felonies a first appeal as a matter of right. In a related area, the Supreme Court has generally been reluctant to uphold claims based on ineffective assistance of counsel.
