POWELL v. ALABAMA
Nine black youths -- described by their attorneys as ignorant and illiterate -- were accused of raping two white women on a freight train headed from Chattanooga to Alabama. Alabama officials sprinted through the legal proceedings: A total of three trials took one day, and all nine were sentenced to death. Alabama law required the appointment of counsel in capital cases, but the attorneys did not consult with their clients and had done little more than appear to represent them at the trial. This case was decided together with Patterson v. Alabama and Weems v. Alabama.
Did the trials violate the Due Process Clause of the Fourteenth Amendment?
Yes. The Court held that the trials denied due process because the defendants were not given reasonable time and opportunity to secure counsel in their defense. Though Justice George Sutherland did not rest the Court holding on the right-to-counsel guarantee of the Sixth Amendment, he repeatedly implicated that guarantee. This case was an early example of national constitutional protection in the field of criminal justice.