Douglas v. California

Facts

Meyes and Douglas (D) were jointly tried and convicted in a California court on an information charging them with 13 felonies. A single public defender was appointed to represent them. At the commencement of the trial, D moved for a continuance, stating that the case was very complicated, that he was not as prepared as he felt he should be because he was handling a different defense every day and that there was a conflict of interest between Ds requiring the appointment of separate counsel for each of them. This motion was denied. Ds eventually dismissed the defender, claiming he was unprepared, and again renewed motions for separate counsel and for a continuance. These motions also were denied, and Ds were ultimately convicted by a jury of all 13 felonies. Both were given prison terms. Ds appealed as of right to the California District Court of Appeal. Douglas (D) requested the assistance of counsel on appeal but was denied even though he was indigent. The Court of Appeal concluded that 'no good whatever could be served by appointment of counsel.' The Court acted under a California rule which provided that state appellate courts, upon the request of an indigent for counsel, may make 'an independent investigation of the record and determine whether it would be of advantage to the defendant or helpful to the appellate court to have counsel appointed. (After) such investigation, appellate courts should appoint counsel if in their opinion it would be helpful to the defendant or the court, and should deny the appointment of counsel only if in their judgment such appointment would be of no value to either the defendant or the court.' That court affirmed their convictions. Ds then petitioned for further discretionary review in the California Supreme Court, but their petitions were denied without a hearing. The Supreme Court granted certiorari. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

© 2007-2024 ABN Study Partner.