Carnley v. Cochran

369 U.S. 506, 82 S. Ct. 884, 8 L. Ed. 2d 70, 1962 U.S. LEXIS 1357
CourtSupreme Court of the United States
DecidedApril 30, 1962
Docket158
StatusPublished
Cited by1,893 cases

This text of 369 U.S. 506 (Carnley v. Cochran) is published on Counsel Stack Legal Research, covering Supreme Court of the United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Carnley v. Cochran, 369 U.S. 506, 82 S. Ct. 884, 8 L. Ed. 2d 70, 1962 U.S. LEXIS 1357 (1962).

Opinions

Mr. Justice Brennan

delivered the opinion of the Court.

The petitioner, who was not afforded the assistance of counsel for his defense at his trial, claims that, for this reason, his conviction by a jury in the Court of Record for Escambia County, Florida, deprived him of rights guaranteed by the Fourteenth Amendment. He obtained a provisional writ of habeas corpus from the Florida Supreme Court on his petition asserting that claim. [507]*507However, that court, on the petition, the respondent's return and the petitioner's reply — but without any hearing — discharged the writ. 123 So. 2d 249. Since an important constitutional right is involved, we granted certiorari and appointed counsel to represent the petitioner in this Court. 366 U. S. 958, 368 U. S. 806.

The assistance of counsel might well have materially aided the petitioner in coping with several aspects of the case. He was charged with the noncapital offenses of incestuous sexual intercourse with his 13-year-old daughter and, in a separate count relating to the same acts, fondling a minor child, that is, assault in a lewd, lascivious, and indecent manner, upon a female child under the age of 14. At the time of trial two sets of Florida criminal statutes contained language reaching such behavior. Sections 741.22 and 800.04, Florida Statutes, 1959, were general criminal provisions separately defining the two offenses of incest and assault in a lewd, lascivious,' and indecent manner. In addition, both offenses were included within the later enacted Chapter 801 of the Florida Statutes— Florida’s so-called Child Molester Act-^-if the victim was 14 years of age or younger.1 The Florida Supreme Court [508]*508plainly conceived the petitioner’s prosecution for both offenses as having been under the Child Molester Act. 123 So. 2d, at 250. While that is an obviously plausible view, a lawyer, but not a layman, might have perceived that because the Child Molester Act was invoked against the petitioner in respect of conduct elsewhere specifically defined as criminal, the 1954 decision of the Florida Supreme Court in Copeland v. State, 76 So. 2d 137, raised doubts, under the Florida Constitution, of the validity of a prosecution based on the Act.2 The picture is further complicated by the fact that the Child Molester Act had included no reference to incest prior to an amendment made subsequent to the petitioner’s alleged offense.3

Establishing the basis of the petitioner’s prosecution was vitally important for the protection of his rights. If the Child Molester Act was validly applied against the [509]*509petitioner, counsel could have materially assisted him by invoking on his behalf the special provisions of that law governing the disposition of defendants charged under it. Sections 741.22 and 800.04 authorize only jail sentences. In contrast, the Child Molester Act empowers the sentencing judge in a proper case to commit the convicted defendant to a Florida state hospital for treatment and rehabilitation.4 That law also permits the accused to [510]*510petition for a psychiatric or psychological examination for the purpose of assisting the court in the trial of the case.5

There are thus present considerations of a sort often deemed sufficient to require the conclusion that a trial for crime without defense counsel did not measure up to the requirements of the Fourteenth Amendment. See, e. g., Chewning v. Cunningham, 368 U. S. 443, 446-447; Reynolds v. Cochran, 365 U. S. 525, 531-532; McNeal v. Culver, 365 U. S. 109, 114-116; Rice v. Olson, 324 U. S. 786, 789-791.

Other aspects of this record also support petitioner’s claim of the unfairness of trying him without affording him the help of a lawyer. As must generally be the case, the trial judge could not effectively discharge the roles of both judge and defense counsel. Here the record shows that the trial judge made efforts to assist the petitioner, but there were important omissions in the guidance he gave. He did not fully apprise the petitioner of vital [511]*511procedural rights of which laymen could not be expected to know but to which defense counsel doubtless would have called attention. The omissions are significant. See, e. g., Cash v. Culver, 358 U. S. 633, 637—638; Gibbs v. Burke, 337 U. S. 773, 776-778; Hudson v. North Carolina, 363 U. S. 697, 702-703. Despite the allegation in respondent’s return that “the petitioners were carefully instructed by the trial court with regard to the rights guaranteed by both the Constitution of Florida and the Constitution of the United States 6 and with regard to the procedures to be followed during the course of the trial,” it appears that, while petitioner was advised that he need not testify, he was not told what consequences might follow if he did testify. He chose to testify and his criminal record was brought out on his cross-examination. For defense lawyers, it is commonplace to weigh the risk to the accused of the revelation on cross-examination of a prior criminal record, when advising an accused whether to take the stand in his own behalf; for petitioner, the question had to be decided in ignorance of this important consideration. Nor does it appear that the trial judge advised the petitioner of his right to examine prospective jurors on voir dire, or of his right to submit proposed instructions to the jury, or of his right to object to the instructions that were given.

Other circumstances attending this case only serve to accentuate the unfairness of trial without counsel. Petitioner is illiterate. He did not interpose a single objection during the trial. The only two witnesses against him were his daughter and a 15-year-old son. Although both petitioner and his wife testified that they had experienced disciplinary problems with the children, and thus clearly revealed a possibly significant avenue for impeachment of [512]*512the children’s testimony, there was no cross-examination worthy of the name.7

We hold that petitioner’s case was one in which the assistance of counsel, unless intelligently and understand[513]*513ingly waived by him, was a right guaranteed him by the Fourteenth Amendment.

We must therefore consider whether the petitioner did intelligently and understanding^ waive the assistance of counsel. The record does not show that the trial judge offered and the petitioner declined counsel. Cf. Moore v. Michigan, 355 U. S. 155, 160-161. Nevertheless, the State Supreme Court imputed to petitioner the waiver of the benefit of counsel on a ground stated in the court’s opinion as follows: “If the record shows that defendant did not have counsel ... , it will be presumed that defendant waived the benefit of counsel . . . .” 123 So. 2d, at 251.

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Cite This Page — Counsel Stack

Bluebook (online)
369 U.S. 506, 82 S. Ct. 884, 8 L. Ed. 2d 70, 1962 U.S. LEXIS 1357, Counsel Stack Legal Research, https://law.counselstack.com/opinion/carnley-v-cochran-scotus-1962.