Which early case held that counsel is not required for some defendants, a decision later overturned?

• A. Gideon v. Wainwright
• B. Escobedo v. Illinois
• C. Powell v. Alabama
• D. Betts v. Brady

Answer: (D)

Right to counsel is a fundamental protection ensuring a fair trial. In Betts v. Brady, the Court held that appointment of counsel for indigent defendants was not required in every criminal case; states could decide case by case, often reserving it for the most serious or complex situations. This meant some defendants might go to trial without a lawyer. This approach stood for years but was later rejected. Gideon v. Wainwright overruled Betts, declaring that the right to counsel is essential to a fair trial and must be provided to defendants who cannot afford one in all criminal prosecutions. To see the progression, Powell v. Alabama had already held that in capital cases defendants must have appointed counsel, highlighting the importance of representation, and Escobedo addresses counsel during police interrogation—not trial—so it doesn’t define trial rights. Thus the early holding that counsel was not required for some defendants is Betts v. Brady, and it was overturned by Gideon.