United States v. Gouveia - 467 U.S. 180, 104 S. Ct. 2292 (1984)

Rule:

U.S. Const. amend. VI guarantees that in all criminal prosecutions, the accused shall enjoy the right to have the assistance of counsel for his defense. The right to counsel attaches only at or after the initiation of adversary judicial proceedings against the defendant. A person's U.S. Const. amend. VI and XIV right to counsel attaches only at or after the time that adversary judicial proceedings have been initiated against him.

Facts:

Defendants, Gouveia Et Al., were four indigent inmates in a federal prison placed in administrative detention during the investigation of the murder of a fellow inmate and remained there for approximately 19 months before they were indicted and arraigned, at which time counsel was appointed for them. Before trial, defendants filed a motion to dismiss the indictments on the ground that their administrative confinement without the appointment of counsel violated their Sixth Amendment right to counsel. The District Court denied their motion, and they were ultimately convicted of murder and conspiracy to commit murder. However, the US Court of Appeals reversed and held that the defendants had a Sixth Amendment right to counsel during the period in which they were held in administrative detention before the return of indictments against them, and that because they had been denied that right, their convictions had to be overturned and their indictments dismissed. On certiorari, the United States Supreme Court reversed and remanded.

Issue:

Were the defendants entitled to fight to counsel under the US Constitution Sixth Amendment?

Answer:

No. The Court reversed a judgment of the appellate court.

Conclusion:

The Court held that the point at which U.S. Const. amend. VI right to counsel was triggered was different in the prosecution of prison crimes. The Court held that U.S. Const. amend. VI right was triggered by the initiation of formal criminal proceedings. The court held that the defendants were not constitutionally entitled to the appointment of counsel while they were in administrative segregation and before any adversary judicial proceedings had been initiated against them. The court pointed out that the Sixth Amendment right to counsel attaches only at or after the initiation of adversary judicial proceedings against the defendant.