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Alabama v. Shelton
United States Supreme Court
535 U.S. 654 (2002)
Shelton (defendant) represented himself at a bench trial and was convicted of third-degree assault. He was given a new trial before a jury, again represented himself, and was again convicted. The court warned Shelton about the perils of representing himself but never appointed counsel for him at the state’s expense. The court sentenced Shelton to 30 days in county prison but immediately suspended the sentence and gave him probation contingent on his payment of court costs. Shelton appealed and argued that because the court did not offer to appoint counsel for him at the state’s expense when there was a chance that he would have to serve the prison term, his Sixth Amendment right to counsel had been violated. The appellate court held that Shelton’s Sixth Amendment right had not been violated because a suspended sentence does not trigger the right to appointed counsel. The Supreme Court of Alabama reversed, holding that a suspended sentence does trigger the right to counsel. The court affirmed Sheldon’s conviction but invalidated the portion of his sentence that imposed prison time. The United States Supreme Court granted certiorari to settle the issue of whether a conditional or suspended sentence entitles the defendant to counsel under the Sixth Amendment.
Rule of Law
Holding and Reasoning (Ginsburg, J.)
Dissent (Scalia, J.)
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