Powell v. Alabama in 1932: Case Brief

Instructor: Anthony Rich

Anthony is currently a County Civil Prosecutor and has his Juris Doctorate. He has been a guest lecturer at several local universities.

Powell v. Alabama established that the court must assign counsel for a defendant in a criminal case when he is unable to employ counsel and is incapable of providing his own defense. Read on to learn more about this case.

Facts of the Case

The time: early 1930s. The place: the Southern United States. A group of young African-American men, nine in total, were on a freight train traveling through Alabama. While on the train they got into a fight with some young caucasian men. The fight resulted in the caucasian men being thrown from the train by the African-American men. After this incident, a message was sent requesting that 'all blacks be removed from the train.'

Also during this train ride, two caucasian females stated that they were raped by six of the young African-American men. The African-American men were taken into custody and charged with the rapes. Being in the South at the time, the local men and women in the community were very upset, and a mob formed when the men were being brought into jail.

At the men's arraignment, or the part in the trial system where they hear the formal charges for the first time, they judge appointed 'all members of the bar.' The young men, or the defendants, were illiterate and could not provide a defense for themselves because none of them knew about the law. The defendants were not told they could hire lawyers and had no access to a lawyer except briefly before the start of their trial. Each of these men were tried separately and each trial lasted only a day. Each of the men were convicted and, at that time in the United States, they could receive and did receive the death penalty.

The defendants appealed to the Alabama Supreme Court and their convictions were upheld. They then appealed to the United States Supreme Court.


There are two issues central to this Supreme Court case.

1.) Were the defendants provided with adequate counsel?

2.) Were the defendants' Due Process Rights violated as guaranteed by the Fourteenth Amendment?


1.) The defendants were not provided with adequate counsel.

2.) The defendants' Due Process Rights were violated by the trial court not allowing them adequate access to their counsel in order to prepare a proper defense.


The court held that the defendants were not provided with adequate counsel because of several factors. The ignorance of the defendants, their illiteracy, their age, and the public's hostile attitude towards them, meant that the trial court should have given the defendants reasonable time to secure counsel and reasonable time and opportunity to prepare a proper defense. Because this was not done, the U.S. Supreme Court ruled that adequate counsel was not given.

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