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# Sixth Amendment Center

## Sitemaps

- [XML Sitemap](https://6ac.org/sitemap.xml): Contains all public & indexable URLs for this website.

## Posts

- [Pleading the Sixth](https://6ac.org/pleading-the-sixth/) - We post commentary on the latest news in the nation about the right to counsel. We also share updates about our work, like when a report from an evaluation is published or groundbreaking legislation passes. Sign up to get alerted on the latest post.
- [Colorado bans flat fees and low hourly rates in certain cases](https://6ac.org/colorado-bans-flat-fees-and-low-hourly-rates-in-certain-cases/) - Pleading the Sixth: On June 6, Colorado Governor Jared Polis signed House Bill 1437 into law, prohibiting municipal governments from paying indigent defense attorneys flat fees and low hourly rates in domestic violence cases. This bill is part of a national trend toward abolishing flat fees and low hourly rates in favor of reasonable hourly
- [Colorado’s progress towards effective representation in municipal courts](https://6ac.org/colorados-progress-towards-effective-representation-in-municipal-courts/) - Pleading the Sixth: Colorado enacts the Fairness & Transparency in Municipal Court Act, banning flat fee contracts (in most instances) and ensuring sufficient time for attorneys to meet clients to prepare arguments for bond in all municipal courts. On April 27, 2026, Governor Jared Polis signed the Fairness & Transparency in Municipal Court Act into
- [Oregon Supreme Court provides relief to unrepresented defendants](https://6ac.org/oregon-supreme-court-provides-relief-to-unrepresented-defendants/) - Pleading the Sixth: The Oregon Supreme Court ruled that the state violates a defendant’s right to counsel under the state constitution when it fails to appoint counsel for more than 60 consecutive days post-arraignment in a misdemeanor and 90 consecutive days in a felony. Emphasizing that the right to counsel is a “core component of
- [Illinois leaves “no state oversight” list with new legislation](https://6ac.org/illinois-leaves-no-state-oversight-list-with-new-legislation/) - Pleading the Sixth: On August 15, 2025, Illinois Governor J.B. Pritzker signed the State Public Defender Act into law, creating the first-ever state commission and state office for trial-level services. This Act is the state’s response to 6AC’s 2021 report and a springboard from which Illinois can hopefully leap towards independence, oversight, and a fair
- [Guam Gains Defender Independence in Unanimous Bipartisan Win](https://6ac.org/guam-gains-defender-independence-in-unanimous-bipartisan-win/) - Pleading the Sixth: Guam gets the job done on much needed reforms thanks to strong bipartisan leadership from all three branches of government. With Acting Governor Josh Tenorio signing 97-38(LS) into law on August 18, 2025, a new independent board with standard-setting authority will now oversee all right to counsel services on Guam. Guam’s leaders
- [Nevada removes political interference from the system](https://6ac.org/nevada-removes-political-interference-from-the-system/) - Pleading the Sixth: Nevada Governor Joe Lombardo signed SB407 into law, releasing control of the state’s public defense system and empowering its independence. This marks the end of a tumultuous year rife with turnover and instability in public defense leadership. Effective tomorrow, July 1, 2025, the Department of Indigent Defense Services (DIDS) Executive Director will
- [Big Public Defense Wins in North Dakota](https://6ac.org/big-public-defense-wins-in-north-dakota/) - Pleading the Sixth: North Dakota Governor Kelly Armstrong signed sweeping legislative reforms into law, securing counsel for in-custody defendants at the first court appearance, discarding public defender application fees, and eliminating the recoupment requirement that indigent defendants must pay back the cost of public defender services. 6AC applauds North Dakota for these great accomplishments! North
- [Onward & Upwards: 6AC Announces New Executive Director and President](https://6ac.org/onward-upwards-6ac-announces-new-executive-director-and-president/) - The Sixth Amendment Center (6AC) announces a new Executive Director, Aditi Goel, ushering in a bold new era for public defense reform and the right to counsel.
- [Gideon is important . . . just not for the reason you think!](https://6ac.org/gideon-is-important-just-not-for-the-reason-you-think/) - Pleading the Sixth: On March 18, our country will celebrate the 62nd anniversary of Gideon v. Wainwright, known as the landmark case for guaranteeing the right to a lawyer. But there is a real danger in assuming that no one in America had the right to a lawyer until 1963 – it can be easily
- [Maine court requires relief for unrepresented defendants](https://6ac.org/maine-court-requires-relief-for-unrepresented-defendants/) - Pleading the Sixth: The Kennebec County Superior Court ruled that the state of Maine is failing to provide attorneys to indigent defendants as required by the Sixth Amendment. The court ordered a couple of methods of relief for unrepresented defendants including release of in-custody defendants if they are detained for more than 14 days without
- [New 6AC report finds South Dakota counties are at a breaking point and need state oversight](https://6ac.org/new-6ac-report-finds-south-dakota-counties-are-at-a-breaking-point-and-need-state-oversight/) - Pleading the Sixth: 6AC and the South Dakota Unified Judicial System release a report after a statewide evaluation of adult trial-level public defense services. The report finds that South Dakota’s locally funded, decentralized county-based public defense system results in the denial of counsel and erodes the adversarial system of justice. However, since January 2023, South
- [Federal district court in Arkansas rules defendants have a right to an attorney at bail hearings  ](https://6ac.org/federal-district-court-in-arkansas-rules-defendants-have-a-right-to-an-attorney-at-bail-hearings/) - Pleading the Sixth: The United States District Court for the Western District of Arkansas found that indigent defendants have a constitutional right to counsel at the bail determination, which is part of Arkansas’s first appearance. In coming to this decision, the court utilized both the facts of the case and evidence-based studies that highlight the
- [2019 Year in Review](https://6ac.org/2019-year-in-review/) - Season’s Greetings from the 6AC! We at 6AC are privileged to travel all across the country to meet with criminal justice stakeholders and policymakers as we aim to help them ensure an effective right to counsel. This year brought us as far north as Anchorage, AK, as far west as Santa Cruz, CA, as far
- [2020 Year in Review](https://6ac.org/2020-year-in-review/) - 2020 brought many challenges to people across the nation. Changes to the ways we work and interact have led many to reassess priorities and focus on how we can improve ourselves and our communities. In that pursuit, courts around the country struggled to balance defendants’ rights to speedy and public trials with the need to
- [2021 Year in Review](https://6ac.org/2021-year-in-review/) - 6AC presents this year in review to acknowledge the most significant reforms to how the right to counsel is funded and delivered across the United States. We wish all our readers a happy and healthy 2022! Indigent defense funding The Kansas State Board of Indigents’ Defense Services (BIDS) provides representation in felonies and appeals through
- [A Cronic resolve to America’s chronic right to counsel deficiencies](https://6ac.org/a-cronic-resolve-to-americas-chronic-right-to-counsel-deficiencies/) - Pleading the Sixth: On September 28, 2016, the Pennsylvania Supreme Court ruled that indigent defendants have a right to challenge systemic deficiencies at the outset of a case before having to suffer from actual or constructive denial of counsel. (Click here for a companion piece on that ruling.) But how does one assess the systemic
- [A lack of effectiveness and financial oversight define Maine’s right to counsel system](https://6ac.org/a-lack-of-effectiveness-and-financial-oversight-define-maines-right-to-counsel-system/) - Pleading the Sixth: Maine is the only state in the country that provides all indigent defense services through private attorneys. There are two principal reasons that other states have moved away from using solely private attorneys. First, it is difficult to predict and contain costs in a private attorney system. Second, it is difficult to supervise
- [A showdown brewing over Early Case Resolution programs in Reno](https://6ac.org/a-showdown-brewing-over-early-case-resolution-programs-in-reno/) - Pleading the Sixth: In January 2008, the Nevada Supreme Court removed the judiciary from the oversight of indigent defense services. On June 8, 2012, a Washoe County (Reno) District Judge tested that mandate with his own administrative order imposing an early case resolution pilot project that will do an end-around the county’s institutional public defenders.
- [ABA clarifies caseload standards for South Carolina prosecutors](https://6ac.org/aba-clarifies-caseload-standards-for-south-carolina-prosecutors/) - Pleading the Sixth: In October 2014, the prosecutors’ association in South Carolina released their 2015-2016 budget request, stating that prosecutors in that state carry 2.5 times the “criminal justice” caseload standards recommended by the American Bar Association (ABA) in seeking a 43% increase in state funding. But wait – the ABA doesn’t have numerical caseload
- [ACLU files federal 6th Amendment class action lawsuit against a Mississippi County](https://6ac.org/aclu-files-federal-6th-amendment-class-action-lawsuit-against-a-mississippi-county/) - Pleading the Sixth: On September 23, 2014, the American Civil Liberties Union (ACLU) filed a complaint in U.S. District Court alleging that Scott County, Mississippi routinely detains felony defendants pre-trial without bail while failing to appoint counsel until after formal indictment which, at best, does not occur until three to five months after arrest. However,
- [ACLU sues Idaho; statutory changes too slow to implement](https://6ac.org/aclu-sues-idaho-statutory-changes-too-slow-to-implement/) - Pleading the Sixth: One June 17, 2015 the American Civil Liberties Union (ACLU) filed a class action lawsuit against the state of Idaho for failing to ensure a meaningful right to counsel. Wait a minute… didn’t the State of Idaho comprehensively fix the right to counsel in 2014 by creating a statewide commission and banning
- [Alabama legislators move to exonerate the Scottsboro Boys](https://6ac.org/alabama-legislators-move-to-exonerate-the-scottsboro-boys/) - Pleading the Sixth: In March 1931, a fight broke out between a group of seven white boys and a larger group of black teenagers aboard a train. When almost all of the white teenagers were thrown off of the slow-moving train, word was sent up ahead to detain the train when it reached Scottsboro, Alabama.
- [Alabama reforms spark expanded use of public defender model](https://6ac.org/alabama-reforms-spark-expanded-use-of-public-defender-model/) - Pleading the Sixth: The indigent defense reforms enacted in 2011 are starting to take root in Alabama. Rather than leading to a proliferation of flat-fee contracting, as some have feared, state funding has steadily increased under the reforms, prompting both Jefferson County (Birmingham) and Montgomery County (Montgomery) to begin creating public defender offices. The February 9th,
- [An Open Letter to the Next Missouri Governor](https://6ac.org/an-open-letter-to-the-next-missouri-governor/) - Pleading the Sixth: On August 2, 2016 the Missouri State Public Defender appointed the Governor to represent an indigent defendant. Whereas, the sitting Governor is term-limited out, the 6AC turns to the two major party nominees with an overview of Missouri’s longstanding constitutional crisis. Dear Mr. Greitens and Mr. Koster, On the very day that
- [Are public defenders better than appointed counsel? DOJ says "yes"](https://6ac.org/are-public-defenders-better-than-appointed-counsel-doj-says-yes/) - Pleading the Sixth: A 2011 report by the United States Department of Justice, Bureau of Justice Statistics concludes that the public defender model provides better, more cost-efficient representation than the assigned counsel model. In a companion piece, the same argument is put forth by two independent research organizations studying indigent defense services in Texas. The Sixth
- [Assembly line pretrial representation in Delaware results in denial of right to counsel](https://6ac.org/assembly-line-pretrial-representation-in-delaware-results-in-denial-of-right-to-counsel/) - In a decision that sounds a warning bell for public defense systems throughout the country, the Delaware Supreme Court has held that “[t]he Sixth Amendment requires more than the physical presence of counsel the first day of trial in a serious felony case with the possibility of a lengthy minimum mandatory incarceration.” Public defense systems often
- [Attorney General Holder calls on Congress to help remedy national indigent defense crisis](https://6ac.org/attorney-general-holder-calls-on-congress-to-help-remedy-national-indigent-defense-crisis/) - Pleading the Sixth: On August 12, 2013, United States Attorney General Eric Holder issued a nationwide challenge to overhaul our “broken” criminal justice system. Bold steps are needed to ensure equal justice, the Attorney General declared, including expanded Congressional right to counsel funding to address the on-going crisis in indigent defense. As a nation, we
- [Broken Defense, a seven-part series exposes the depths of the indigent defense crisis in western states](https://6ac.org/broken-defense-a-seven-part-series-exposes-the-depths-of-the-indigent-defense-crisis-in-western-states/) - Pleading the Sixth: Last week, Lee Enterprises published a seven-part series exposing the indigent defense crisis in the West. With data finally showing what the 6AC has known for years and has found in nearly every study – thousands of unrepresented defendants going to jail without ever speaking to a lawyer – Lee Enterprises brings
- [California’s lack of oversight adds to Santa Cruz County’s indigent defense woes](https://6ac.org/californias-lack-of-oversight-adds-to-santa-cruz-countys-indigent-defense-woes/) - Pleading the Sixth: For decades, Santa Cruz County has delegated to private law firms, through county contracts, all decision-making about the provision of Sixth Amendment right to counsel services. The county cannot accurately say how many people or cases, and of what case types, require appointed counsel nor by whom the representation is being provided, if
- [Calm down; the New Mexico Supreme Court did not say flat-fee contracts are always constitutional](https://6ac.org/calm-down-the-nm-supreme-court-did-not-say-flat-fee-contracts-are-always-constitutional/) - Pleading the Sixth: Though press reports are generally touting a recent New Mexico Supreme Court opinion as declaring flat fee contracting to be constitutional, the reality is more nuanced. The 6AC walks the reader through the historical background for the decision and analyzes what the opinion really means. On June 2, 2016, the New Mexico
- [Coalition of legal experts petitions Wisconsin Supreme Court to end financial conflicts of interest between attorneys and indigent clients](https://6ac.org/coalition-of-legal-experts-petitions-wisconsin-supreme-court-to-end-financial-conflicts-of-interest-between-attorneys-and-indigent-clients/) - Pleading the Sixth: A coalition of legal experts petitions the Wisconsin Supreme Court to end financial conflicts of interest between private attorneys and the indigent clients they are appointed to represent. They ask the state’s high court to ban flat fee contracts and increase hourly rates for assigned counsel from the $40 per hour that
- [Defense leader uses the world stage to expose Congress’ failure to stem America’s indigent defense crisis](https://6ac.org/defense-leader-uses-the-world-stage-to-expose-congress-failure-to-stem-americas-indigent-defense-crisis/) - Pleading the Sixth: A keynote address by the director of the New York State Office of Indigent Legal Services at The Hague on April 5, 2014, served as an indictment of the right to counsel in America and of the absence of a comprehensive, nationwide plan from the federal government in response to the ongoing
- [Delaware’s right to counsel deficiencies exposed](https://6ac.org/delawares-right-to-counsel-deficiencies-exposed/) - Pleading the Sixth: In January 2011, then-Chief Justice Myron Steele sought to end Delaware’s undue judicial interference in the state’s conflict indigent defense services by transferring responsibility for the administration of the conflict panel from the court to the Office of the Public Defender (OPD). Unfortunately, OPD was in no position to take on the
- [DOJ announces an agreement with Shelby County, Tennessee (Memphis) to reform juvenile justice system](https://6ac.org/doj-announces-an-agreement-with-shelby-county-tennessee-memphis-to-reform-juvenile-justice-system/) - Pleading the Sixth: On December 18, 2012, the U.S. Department of Justice announced an agreement with Shelby County, Tennessee (Memphis) to usher in major reforms of the county’s juvenile court system and the method for representing children in delinquency proceedings. Sweeping changes are afoot, including systemic safeguards, such as “independence,” “reasonable caseloads,” “attorney performance standards,”
- [DOJ finds a lack of due process for children in Memphis delinquency courts](https://6ac.org/doj-finds-a-lack-of-due-process-for-children-in-memphis-delinquency-courts/) - Pleading the Sixth: (Part 1 of a two-part series.) The United States Department of Justice, Civil Rights Division (DOJ-CRD) delivered a report to Shelby County, Tennessee (Memphis) in April 2012 stating the Juvenile Court of Memphis and Shelby County (JCMSC) fails to ensure a meaningful right to counsel for children in delinquency proceedings. The Sixth Amendment
- [DOJ recommendations for Shelby County, TN place financial burden on the county; Task Force would place responsibility on the state](https://6ac.org/doj-recommendations-for-shelby-county-tn-place-the-financial-burden-on-the-county-task-force-would-place-responsibility-on-the-state/) - Pleading the Sixth: For nearly five years, the U.S. Department of Justice has been trying to improve the representation of children in delinquency proceedings in Shelby County (Memphis), Tennessee. As the DOJ seeks to put more indigent defense funding responsibilities on Shelby County, the plan is running counter to funding changes recommended by the Supreme Court
- [Exploring the link between over-incarceration and a deficient right to counsel](https://6ac.org/exploring-the-link-between-over-incarceration-and-a-deficient-right-to-counsel/) - Pleading the Sixth: A recent report by the PEW Center on the States concludes that states wasted $10 billion incarcerating people with little impact on public safety to show for the investment. The Sixth Amendment Center adds to the story by linking the long-standing right to counsel systemic deficiencies to the high cost of corrections,
- [Federal committee recommends independence of the defense function](https://6ac.org/federal-committee-recommends-independence-of-the-defense-function/) - Pleading the Sixth: Kept under wraps since being issued in November 2017, the report of the committee appointed by U.S. Supreme Court Chief Justice Roberts to study the provision of the Sixth Amendment right to counsel in the federal courts was released today. Foremost among its recommendations is that Congress must act to ensure that
- [Federal Court orders Washington cities to remedy willfully deficient right to counsel services](https://6ac.org/federal-court-orders-washington-cities-to-remedy-willfully-deficient-right-to-counsel-services/) - Pleading the Sixth: A U.S. District Court found in early December that two Washington cities are responsible for the systemic deficiencies depriving the indigent accused of their constitutional right to meaningful representation. In granting injunctive relief, the Court determined the steps needed to be taken to ensure that the criminal justice system be appropriately adversarial.
- [Flaws in West Virginia indigent defense system result in non-lawyer representing indigent defendants](https://6ac.org/flaws-in-west-virginia-indigent-defense-system-result-in-non-lawyer-representing-indigent-defendants/) - Pleading the Sixth: In Logan County, West Virginia, a recent law school graduate who never passed the bar exam was allowed to represent the indigent accused in misdemeanor court. This is an obvious violation of the Sixth Amendment right to counsel, and it exposes flaws in the structure of West Virginia’s indigent defense system. In
- [Florida institutes a “dangerous game of chance” in conflict representation](https://6ac.org/florida-institutes-a-dangerous-game-of-chance-in-conflict-representation/) - Pleading the Sixth: A new Florida statute allows judges to limit compensation for private attorneys handling conflict indigent defense cases. A June 2012 Florida Innocence Commission report says the law “invites ineffective assistance of counsel and wrongful convictions.” As some circuits impose the new requirements, the Florida Association of Criminal Defense Lawyers seeks to have
- [Georgia consent decree requires competent counsel for children and adults](https://6ac.org/georgia-consent-decree-requires-competent-counsel-for-children-and-adults/) - The right to counsel for children and adults in four counties in Georgia should soon be much closer to meeting minimum constitutional demands. The structural changes will come about as the result of a class action lawsuit challenging the effectiveness of a four-county public defense system in which defendants were routinely denied a fair day
- [How an otherwise model assigned counsel compensation plan contributes to South Dakota’s indigent defense problems](https://6ac.org/how-an-otherwise-model-assigned-counsel-compensation-plan-contributes-to-south-dakotas-indigent-defense-problems/) - Pleading the Sixth: When states make counties wholly responsible for the delivery of trial-level indigent defense services without state oversight of those services, bad things can and do happen. In Part I of this two-part report, the 6AC looks at South Dakota’s decentralized right to counsel system, and the resulting impact on the client community. In
- [How public defenders struggle with ethical blindness](https://6ac.org/how-public-defenders-struggle-with-ethical-blindness/) - Pleading the Sixth: Do psychological factors force public defenders to rationalize sub-par performance in the face of excessive caseloads? And are these unconscious phenomena responsible for the failure to institutionalize caseload controls? These are just a few of the questions 6AC's David Carroll explores with former public defender and current New England Law Professor, Tigran
- [Idaho Chief Justice calls for the eradication of flat fee contracts](https://6ac.org/idaho-chief-justice-calls-for-the-eradication-of-flat-fee-contracts/) - Pleading the Sixth: On August 15, 2013, the Chief Justice of Idaho addressed a legislative committee charged with studying the need for state involvement in the oversight and administration of right to counsel services. Calling for the eradication of flat fee contracts, the Chief Justice advocated for a return to Idaho’s historical roots of providing
- [Idaho empowers state commission with new authority and new funding](https://6ac.org/idaho-empowers-state-commission-with-new-authorities-and-new-funding/) - Pleading the Sixth: On the heels of Utah’s comprehensive reform, the Idaho legislature steps up and empowers the state indigent defense commission created in 2014 to promulgate and enforce binding standards. The carrot for counties to comply comes in the form of significant new state funding ($5.4 million) to help local systems meet standards. Importantly, Idaho
- [Idaho Governor signs public defense commission bill into law](https://6ac.org/idaho-governor-signs-public-defense-commission-bill-into-law/) - Pleading the Sixth: Idaho became the 23rd state to create a statewide public defender commission overseeing right to counsel services when the Governor signed a reform bill into law after it overwhelmingly passed both chambers of the legislature. Though the Governor also signed a budget bill giving the nascent commission start-up money, a second reform bill
- [Idaho legislature contemplates initial reforms](https://6ac.org/idaho-legislature-contemplates-initial-reforms/) - Pleading the Sixth: The Idaho Criminal Justice Commission offered initial indigent defense reforms that have been introduced in the House of Representatives. The proposed reforms seek to, among other things: create a statewide uniform standard for who may get public counsel; clarify the types of cases to which the right to counsel attaches; to bar children
- [Idaho passes initial reforms; Second round of reforms introduced](https://6ac.org/idaho-legislature-pass-initial-reforms-second-round-of-reforms-introduced/) - Pleading the Sixth: The Idaho Senate unanimously passed an initial indigent defense reform package, sending it on for the Governor’s signature. Not content to rest with creating a uniform standard of indigency and barring children from waiving counsel, among others reforms, a concurrent resolution also passed the House and was voted favorably our of Senate
- [In wake of 6AC report, legislative changes are already afoot in Utah](https://6ac.org/in-wake-of-6ac-report-legislative-changes-are-already-afoot-in-utah/) - Pleading the Sixth: On the heels of the 6AC report, the Utah Judicial Council adopted a report on October 26, 2015, by an indigent defense study committee calling for significant state actions, including a statewide commission with authority to set standards (workload, performance, attorney qualifications, etc.) and monitor compliance, the first-ever statewide funding, and a
- [Independence jeopardized with public defender reorganization plan in King County, Washington](https://6ac.org/independence-jeopardized-with-public-defender-reorganization-plan-in-king-county-washington/) - Pleading the Sixth: King County, Washington (Seattle) released a plan for the reorganization of its right to counsel system. Long-regarded as an indigent defense “best practice” jurisdiction, the County proposes to eliminate independence while transitioning the staff of the four non-profit public defender agencies to county employees. King County points to other jurisdictions, like Los
- [Independence threatened as public defenders strive for parity in King County, Washington](https://6ac.org/independence-threatened-as-public-defenders-strive-for-parity-in-king-county-washington/) - Pleading the Sixth: In 2011, the Washington State Supreme Court affirmed a lower court ruling that employees of the four independent, non-profit public defense organizations in King County (Seattle) must be considered as county employees for the purposes of participation in the public employee retirement fund. As a settlement in the case looms, King County
- [Indiana stands as a cautionary tale for other states with similar indigent defense system models](https://6ac.org/indiana-stands-as-a-cautionary-tale-for-other-states-with-similar-indigent-defense-system-models/) - Pleading the Sixth: On October 24, 2016, the Sixth Amendment Center released its report detailing how the “Indiana Model” for defender services leads to the actual denial of counsel and/or the provision of a lawyer in name only throughout the state. (See Part I of this two-part series.) Here, the 6AC shows how predominant aspects of the
- [Indiana Task Force on Public Defense urges comprehensive reform](https://6ac.org/indiana-task-force-on-public-defense-urges-comprehensive-reform/) - Pleading the Sixth: In October 2016, the 6AC released its evaluation of trial level right to counsel services in Indiana, detailing how and why the Indiana public defense system results in the actual and constructive denial of counsel to the indigent accused in courts all across the state. In 2017, an independent 17-member Indiana Task Force
- [Indigent defense bill introduced in Michigan legislature](https://6ac.org/indigent-defense-bill-introduced-in-michigan-legislature/) - Pleading the Sixth: A sweeping indigent defense reform bill was introduced in the Michigan legislature on August 15, 2012 that promises to bring accountability to and improve the quality of right to counsel services in the state. Initial signs are positive as 68% of the House of Representatives have already signed on as co-sponsors. The Sixth Amendment
- [Indigent Defense in the Wild West](https://6ac.org/indigent-defense-in-the-wild-west/) - In March 2013, 6AC released its report Reclaiming Justice telling the story of how accused stagecoach robber, Shepherd L. Wixom, fought for the right to have an attorney to advocate on his behalf, and how the reaction of the Nevada legislature and state supreme court to secure a fair day in court for poor people far predates any
- [Indigent defense progress stunted by outdated funding mechanism in Louisiana](https://6ac.org/indigent-defense-progress-stunted-by-out-dated-funding-mechanism-in-louisiana/) - Pleading the Sixth: The chairman of the Louisiana Public Defender Board (LPDB) warns that the state’s reliance on unpredictable revenue streams to fund the right to counsel makes public defense service restrictions “inevitable” in the coming months. A new report on the dire financial situation of New Orleans’ public defender office serves to underscore this
- [Judges’ removal of Champaign County public defender sets off alarms in Illinois](https://6ac.org/judges-removal-of-champaign-county-public-defender-sets-off-alarms-in-illinois/) - Pleading the Sixth: Illinois statutes authorize circuit judges to control the public defense function. In every one of Illinois’ 102 counties, except Cook (Chicago), circuit judges hire the public defender and can fire the public defender for any reason or no reason. In order to preserve the independence of the public defense function and ensure
- [Louisiana’s right to counsel problems explained](https://6ac.org/louisianas-right-to-counsel-problems-explained/) - Pleading the Sixth: The aims of public safety are in conflict with the need for law enforcement to generate indigent defense revenue in Louisiana. But as Louisiana’s problems have become a major focal point of America’s broader right to counsel crisis, media outlets have failed to underscore a key failing: local judges have no authority
- [Maine Commission on Indigent Legal Services to run out of money in April 2013](https://6ac.org/maine-commission-on-indigent-legal-services-to-run-out-of-money-in-april-2013/) - Pleading the Sixth: The Maine Commission on Indigent Legal Services (MCILS) is predicting that it will run out of money to pay assigned counsel attorneys shortly after the 50th Anniversary of Gideon v. Wainwright (March 2013). The unavailability of funds, combined with low hourly rates, is causing attorneys to leave the system even as the
- [Maryland OPD receives 7.4% budget increase to staff bail hearings](https://6ac.org/maryland-opd-receives-7-4-budget-increase-to-staff-bail-hearings/) - Pleading the Sixth: In DeWolfe v. Richmond, the Maryland Supreme Court found that existing statutes require the right to counsel at bail hearings and reviews. The General Assembly reacted by increasing the budget of the Office of the Public Defender nearly 7.4% while contemporaneously passing legislation requiring police to issue citations – rather than arrest and detention
- [Michigan clears first legislative hurdle on way to reforming indigent defense](https://6ac.org/michigan-clears-first-legislative-hurdle-on-way-to-reforming-indigent-defense/) - Pleading the Sixth: On September 19, 2012, the Michigan House Judiciary Committee favorably voted the indigent defense reform bill on to the full House on an overwhelmingly bi-partisan basis. A week earlier, the bill was almost derailed in the committee by testimony from a representative of the Office of the Attorney General. Read about the
- [Michigan Court of Appeals allows class action lawsuit to proceed](https://6ac.org/michigan-court-of-appeals-allows-class-action-lawsuit-to-proceed/) - Pleading the Sixth: On April 3, 2013, the Michigan Court of Appeals affirmed a lower court’s ruling denying the state’s motion to dismiss the American Civil Liberties Union’s class action lawsuit alleging systemic deficiencies to the delivery of constitutionally mandated right to counsel services. As key legislators prepare to file a new comprehensive public defender
- [Michigan Governor’s Advisory Commission recommends sweeping changes](https://6ac.org/michigan-governors-advisory-commission-recommends-sweeping-changes-2/) - Pleading the Sixth: On June 22, 2012, a high-profile, bi-partisan commission appointed by Michigan Governor Rick Snyder unanimously adopted a set of findings and recommendations that will change the way the state provides right to counsel services, if legislatively passed in the coming months. A permanent, independent commission with authority to establish and enforce minimum standards
- [Michigan is ripe for another giant leap toward fulfilling its right to counsel obligations](https://6ac.org/michigan-ripe-for-more-reforms/) - Pleading the Sixth: A 6AC report finds Oakland County, Michigan’s indigent defense system pits assigned counsels’ financial self-interests against the legal interests of their indigent clients while excess caseloads go unchecked under a county system that lacks adequate oversight and supervision. The report concludes that the structural deficiencies identified within Oakland County at root are
- [Michigan passes public defense reform legislation](https://6ac.org/michigan-passes-public-defense-reform-legislation/) - Pleading the Sixth: On June 13, 2013 the Michigan Legislature passed separate yet identical right to counsel reform bills in each chamber of the legislature. On June 19th, the Michigan Senate held a concurrence vote on the House version of the bill, overwhelmingly endorsing it and sending on to Governor Rick Snyder for his signature.
- [Mississippi’s “dead zone” highlights the urgent need for state-level reforms](https://6ac.org/mississippis-dead-zone-highlights-the-urgent-need-for-state-level-reforms/) - Pleading the Sixth: Mississippi regularly denies felony defendants the right to counsel during the critical stage between arrest or preliminary hearing and arraignment following grand jury indictment. This practice is pervasive, resulting from systemic neglect of indigent defense at the state level. Until Mississippi provides state-level oversight to guarantee that local governments are both capable
- [Missouri Bar weighs in on workload crisis as the legislature debates privatizing much of the public defender’s work](https://6ac.org/missouri-bar-weighs-in-on-workload-crisis-as-the-legislature-debates-privatizing-much-of-the-public-defenders-work/) - Pleading the Sixth: A new bill introduced in the Missouri legislature would resolve the public defender caseload crisis by restricting the state public defender to representation in only serious felony cases while privatizing services for all other case-types through low-bid contracts. The Missouri Bar’s, Criminal Justice Task Force also weighs in with its own recommendations,
- [Missouri Governor shows why indigent defense crisis will not be fixed without defender independence](https://6ac.org/missouri-governor-shows-why-indigent-defense-crisis-will-not-be-fixed-without-defender-independence/) - Pleading the Sixth: When the Missouri Public Defender, Michael Barrett, appointed the Governor to represent an accused indigent defendant, it brought national attention to the state’s longstanding underfunding of right to counsel services. Now, after a local judge ruled Barrett lacked the authority to take the action he did, the Governor moved to change the
- [Missouri prosecutors claim new audit report proves defender caseload woes are a manufactured myth](https://6ac.org/missouri-prosecutors-claim-new-audit-report-proves-defender-caseload-woes-are-a-manufactured-myth/) - Pleading the Sixth: On October 10, 2012, the Missouri state auditor released a report on the state public defender system that the Missouri Association of Prosecuting Attorneys claims “shatters the unsupported claims” of excessive caseloads across the state and accuses the public defender of manufacturing a workload crisis “myth.” The Sixth Amendment Center read the
- [Missouri’s “Perfect Storm” explained](https://6ac.org/missouris-perfect-storm-explained/) - Pleading the Sixth: As if excessive caseloads, a lack of independence, inadequate funding, and low compensation were not enough of a problem for those charged with providing right to counsel services in Missouri, public defenders are now being forced into a Hobson’s choice: either provide ineffective representation and lose one’s law license, or refuse assignments
- [MO prosecutors take issue with state court decision on PD caseload controls](https://6ac.org/mo-prosecutors-take-issue-with-state-court-decision-on-pd-caseload-controls/) - Pleading the Sixth: (Part 2 of a two-part series.) On July 31, 2012, the Missouri Supreme Court ruled that the state public defender commission has the authority to declare unavailability due to case overload. In response, the Missouri Association of Prosecuting Attorneys issued a press statement on August 3rd that the “public defender system is not
- [MO Supreme Court rules that public defense commission can decline cases](https://6ac.org/mo-supreme-court-rules-that-public-defense-commission-can-decline-cases/) - Pleading the Sixth: (Part 1 of a two-part series.) On July 31, 2012, the Missouri Supreme Court ruled that the state public defender commission has the authority to declare unavailability due to case overload. In response, the Missouri Association of Prosecuting Attorneys issued a press statement on August 3rd that the “public defender system is not
- [Montana caseload challenge results in a significant increase in resources](https://6ac.org/montana-caseload-challenge-results-in-a-significant-increase-in-resources/) - Pleading the Sixth: In September 2013, the Montana Office of the State Public Defender filed a motion seeking to decline new cases in two courts of limited jurisdiction. Though the lower court found in October of that year that it did not have the authority to grant relief, a subsequent appeal was put on hold
- [Montana State Public Defender files motion to decline new cases](https://6ac.org/montana-state-public-defender-files-motion-to-decline-new-cases/) - Pleading the Sixth: In September 2013, the Montana Office of the State Public Defender filed a motion seeking to decline new cases in two courts of limited jurisdiction. A hearing date set for early October was postponed when a city and a county prosecutor filed briefs challenging the motion. As advocates await a new court
- [National Center for the Right to Counsel bill entered in U.S. House](https://6ac.org/national-center-for-the-right-to-counsel-bill-entered-in-u-s-house/) - Pleading the Sixth: On October 30, 2013, U.S. Representative Ted Deutch entered a bill to create a federally funded National Center for the Right to Counsel to aid states in meeting their constitutional obligations under Gideon. Though a national center providing grants and technical assistance to states has been talked about for decades, Rep. Deutch’s leadership
- [Nevada Chief Justice: “We must do better at providing representation to rural defendants.”](https://6ac.org/nevada-chief-justice-we-must-do-better-at-providing-representation-to-rural-defendants/) - Pleading the Sixth: In his State of the Judiciary address, Nevada’s Chief Justice decried the growing justice gap in right to counsel services between urban and rural jurisdictions in his state. Announcing that rural counties simply cannot shoulder the state’s Sixth Amendment obligations any longer, the Chief Justice challenged the legislature to create a statewide
- [Nevada creates and empowers a statewide indigent defense commission](https://6ac.org/nevada-creates-and-empowers-a-statewide-indigent-defense-commission/) - Pleading the Sixth: After decades of public defense studies, legislative and supreme court right to counsel commissions, and numerous attempts at statutory indigent defense reform, the Nevada legislature has created a state commission to promulgate and enforce uniform standards statewide for providing indigent defense representation. Although the bill was stripped of significant appropriations at the
- [Nevada Supreme Court bans flat fee contracting](https://6ac.org/nevada-supreme-court-bans-flat-fee-contracting/) - Pleading the Sixth: On July 23, 2015, the Nevada Supreme Court banned the use of flat fee contracts in the provision of indigent defense services. The same order endorses the statewide commission format. Will the order force legislative change? The 6AC explains what has been happening in Nevada over the past year. Announcing that the
- [Nevada Supreme Court issues order on early case resolution](https://6ac.org/nevada-supreme-court-issues-order-on-early-case-resolution/) - Pleading the Sixth: A huge victory for right to counsel advocates in Nevada will most assuredly cause reverberations across the country. More than a year after the public defenders in Reno asked the Nevada Supreme Court to rescind a district judge’s order authorizing an early case resolution (ECR) project that did an end-around the county’s
- [New Jersey abolishes public defender reimbursement fees in felony cases](https://6ac.org/new-jersey-abolishes-public-defender-reimbursement-fees-in-felony-cases/) - Pleading the Sixth: A recent change in state law means that indigent felony defendants in New Jersey will no longer have to pay public defender reimbursement fees; and any outstanding public defender reimbursement fees, liens, or warrants are forgiven. New Jersey is the ninth state in the country to abolish public defender reimbursement fees and
- [New Mexico becomes 20th state with independent public defense commission](https://6ac.org/new-mexico-becomes-20th-with-independent-statewide-public-defense-commission/) - Pleading the Sixth: On April 5, 2013, the Governor of New Mexico signed a public defender commission bill into law signaling the end of the political practices that led to instability in the chief public defender position. Will this day mark the end of undue political interference of the right to counsel in that state?
- [New Mexico legislature begins work on public defender commission bill](https://6ac.org/new-mexico-legislature-begins-work-on-public-defender-commission-bill/) - Pleading the Sixth: On November 6, 2012, the New Mexico electorate passed a constitutional amendment requiring the creation of an independent public defender commission. In anticipation of the next legislative session, the House Committee for the Courts, Corrections and Justice held an initial hearing on November 30th to debate a new commission’s appointing authorities and
- [New Mexico voters to decide fate of public defender independence](https://6ac.org/new-mexico-voters-to-decide-fate-of-public-defender-independence/) - Pleading the Sixth: Advocates in New Mexico have tried for years to insulate the state public defender from undue political interference with no success. So now the voters will decide whether to amend the state constitution to require the legislature to create an independent, statewide public defender commission. Three of the four largest newspapers in
- [New Mexico’s independent state commission is a “complete game changer”](https://6ac.org/new-mexicos-independent-state-commission-is-a-complete-game-changer/) - Pleading the Sixth: The New Mexico chief public defender recently requested the state legislature for a 21% increase in funding. Ten years ago, the chief public defender was fired a week after telling lawmakers that the system was underfunded. 6AC examines how the creation of an independent oversight commission in 2013 now makes it possible
- [New Michigan public defense reform bill introduced](https://6ac.org/new-michigan-public-defense-reform-bill-introduced/) - Pleading the Sixth: Is 2013 the year that Michigan finally passes substantial right to counsel reform? In a two-part series, the 6AC discusses a new indigent defense reform bill introduced in the state legislature on April 10, 2013. Part One analyzes how the proposed bill meets the vast majority of the ABA Ten Principles, and
- [New report exposes systemic deficiencies in New Hampshire’s administration and oversight of indigent defense representation](https://6ac.org/report-exposes-systemic-deficiencies-in-new-hampshire/) - Pleading the Sixth: A new study shows that New Hampshire’s indigent defense system lacks adequate funding and structure to ensure that each indigent defendant receives constitutionally required effective assistance of counsel. The New Hampshire Judicial Council, the entity responsible for administering and overseeing the state’s indigent defense system, lacks independence and lacks adequate funding and
- [New report finds State of Michigan must take responsibility for deficient felony assigned counsel services in Wayne County (Detroit)](https://6ac.org/new-report-finds-state-of-michigan-must-take-responsibility-for-deficient-felony-assigned-counsel-services-in-wayne-county-detroit/) - Pleading the Sixth: Forcing trial court judges to design and directly oversee the system that provides attorneys to represent indigent defendants always opens the door to the dangers of undue judicial interference with the right to counsel. This is the case in Wayne County (Detroit), Michigan, as explained in a new 6AC report evaluating the way
- [New reports promote public defender model for Texas](https://6ac.org/new-reports-promote-public-defender-model-for-texas/) - Pleading the Sixth: Two new independent reports out of Texas conclude that the public defender model provides better, more cost-efficient representation than the assigned counsel model. In a companion piece, a 2011 U.S. Department of Justice report makes the same argument. The Sixth Amendment Center read all three reports and reached a very different conclusion. On
- [New York caseload standards announced and their importance to statewide reform explained](https://6ac.org/new-york-caseload-standards-announced-in-wake-of-state-funding-agreement/) - Pleading the Sixth: In early April 2017, the New York governor’s office and legislature reached a historic legislative agreement. The state of New York is already committed to pay for the systemic reforms promulgated pursuant to the settlement agreement in the NYCLU class action lawsuit in five upstate counties. Under the new legislation, the state
- [North Carolina’s independence issue exposed](https://6ac.org/north-carolinas-independence-issue-exposed/) - Pleading the Sixth: Not all statewide commissions are equal. For many years, the North Carolina Commission for Indigent Defense Services has been upheld as an example of how best to create a statewide public defender commission. After all, when it comes to the size, composition and diversity of the Commission itself, for the most part,
- [Oil boom rapidly creating a Sixth Amendment crisis in North Dakota](https://6ac.org/oil-boom-rapidly-creating-a-sixth-amendment-crisis-in-north-dakota/) - Pleading the Sixth: Though the successful implementation of oil fracking technologies has created a large budget surplus for North Dakota, it has also had the unintended side effect of overwhelming the state’s indigent defense system, as unemployed workers from across the country flood oil “boom towns” in the northwest regions of the state that were
- [Oregon’s complex bureaucracy obscures just another fixed fee system](https://6ac.org/oregons-complex-bureaucracy-obscures-just-another-fixed-fee-system/) - Pleading the Sixth: Oregon stands as a cautionary tale regarding indigent defense reform. Often extolled (including by this author) as a working model that provides effective public defense services through a statewide system of contracts, a new comprehensive evaluation by the 6AC reveals instead that Oregon constructed a complex bureaucracy that at root is simply
- [Pennsylvania is off the “no state funding” list. Is South Dakota next?](https://6ac.org/pennsylvania-is-off-the-no-state-funding-list-is-south-dakota-next/) - Pleading the Sixth. At the start of 2023, Pennsylvania and South Dakota were the last two states remaining to contribute no funding to indigent defense. This morning, Pennsylvania is no longer on that list. And just last week, the South Dakota Governor publicly supported increasing the state’s role in indigent defense in response to a
- [Pennsylvania Supreme Court recognizes indigent defendants' right to sue before receiving ineffective representation](https://6ac.org/pennsylvania-supreme-court-recognizes-indigents-right-to-sue-before-receiving-ineffective-representation/) - Pleading the Sixth: On September 28, 2016, the Pennsylvania Supreme Court ruled that indigent defendants have the right to challenge systemic deficiencies at the outset of a case before having to suffer from actual or constructive denial of counsel. Moreover, the Court affirmed that ineffective representation is “all but certain” system-wide throughout Pennsylvania, in ruling that
- [Politico & The Marshall Project profile the work of the 6AC](https://6ac.org/politico-profiles-the-work-of-the-6ac/) - Pleading the Sixth: I am honored to have the work of the Sixth Amendment Center (6AC) featured by POLITICO and The Marshall Project. At a time when American political discourse is too much defined by opposing factions standing on soapboxes yelling at each other, the 6AC stands apart. We bring unlikely allies together to overcome the deficiencies
- [Proposed Michigan legislation gives prosecutors a voice on indigent defense commission](https://6ac.org/posed-michigan-legislation-gives-prosecutors-a-voice-on-indigent-defense-commission/) - Pleading the Sixth: On April 10, 2013, two identical public defense reform bills were introduced in both chambers of the Michigan legislature. The bill gives the Prosecuting Attorneys Association of Michigan (PAAM) an appointment to the Michigan Indigent Defense Commission (MIDC). Part One of this series details information on the duties and responsibilities of the
- [Putting the spotlight on small-town America: Putnam County, Indiana](https://6ac.org/putting-the-spotlight-on-small-town-america-putnam-county-indiana/) - Pleading the Sixth: In holding that the right to the assistance of counsel is a guarantee of our federal Constitution, the U.S. Supreme Court in Gideon v. Wainwright made that right obligatory on state governments by virtue of the Fourteenth Amendment – it was not an obligation of the courts, nor the duty of the
- [Redefining the right to counsel in Tennessee](https://6ac.org/redefining-the-right-to-counsel-in-tennessee/) - The voice of the people is negated on indigent defense in Tennessee. The 6AC points to a new way forward in resolving long-standing structural deficiencies in the state's district defender conference model. https://vimeo.com/110144223 Read more on this topic: Pleading the Sixth: Tennessee undermines own values in providing counsel to the poor.
- [Report released evaluating the right to counsel in rural Nevada](https://6ac.org/report-released-evaluating-the-right-to-counsel-in-rural-nevada/) - Pleading the Sixth: Remote population centers across great geographic expanses, a paucity of attorneys, limited social services, almost no public transportation, restricted tax bases, and non-lawyer judges in misdemeanor courts, are just some of the problems states often face while trying to provide effective public defense services in rural America. These problems are exacerbated in
- [Revised ABA Ten Principles: A new public defense roadmap for policymakers](https://6ac.org/revised-aba-ten-principles-a-new-public-defense-roadmap-for-policymakers/) - Pleading the Sixth: On August 7, 2023, the American Bar Association (ABA) passed a revision of the ABA Ten Principles of a Public Defense Delivery System, giving policymakers a new roadmap for providing public defense. The Ten Principles is revised after 21 years and comes at the perfect time. Independent state oversight, statewide data collection,
- [Right to counsel advocates mourn the passing of Anthony Lewis](https://6ac.org/right-to-counsel-advocates-mourn-the-passing-of-anthony-lewis/) - Pleading the Sixth: On March 25, 2013 the indigent defense community lost one of its heroes. Anthony Lewis, the author of Gideon’s Trumpet, passed away at his home in Cambridge, Massachusetts at the age of 85. From time to time – with due solemnity, and after much searching of conscience – the Court has overruled its
- [SCOTUS decision exposes unequal justice for Native Americans](https://6ac.org/scotus-decision-exposes-unequal-justice-for-native-americans/) - Pleading the Sixth: On June 13, 2016, the U.S. Supreme Court held that prior uncounselled tribal court convictions resulting in jail time can be used to enhance penalties on subsequent offenses in federal courts. Wait! Isn't that the exact opposite conclusion the Court reached regarding uncounselled convictions from state and federal courts? Why the double standard for poor
- [Senator Grassley believes indigent defense system needs reform](https://6ac.org/senator-grassley-believes-indigent-defense-system-needs-reform/) - Senator Chuck Grassley (R) of Iowa, Chairman of the Senate Judiciary Committee, spoke about the need for indigent defense reform during his remarks at the National Press Club Newsmakers News Conference on April 27. Sen. Grassley emphasized the importance of helping “indigent defendants who are not being provided with counsel as the Constitution requires,” explaining
- [Shelby County, TN (Memphis) faces difficult decisions in the wake of critical DOJ report](https://6ac.org/shelby-county-faces-difficult-decisions-in-the-wake-of-critical-doj-report/) - Pleading the Sixth: (Part 2 of a two-part series.) The United States Department of Justice, Civil Rights Division (DOJ-CRD) delivered a report to Shelby County, Tennessee (Memphis) in April 2012 stating the local court fails to ensure due process to children in delinquency courts. The Sixth Amendment Center discusses the implications for future changes to juvenile representation
- [Should non-lawyer judges be sending people to jail? SCOTUS asked to review](https://6ac.org/should-non-lawyer-judges-be-sending-people-to-jail-scotus-asked-to-review/) - Pleading the Sixth: In 1976, the U.S. Supreme Court determined that the Fourteenth Amendment permits non-lawyer judges to impose jail time so long as the defendant has the ability to get a do-over in front of a judge who is a lawyer. Now the Court is asked to clarify whether due process concerns allow non-lawyer
- [State of New York to provide full state funding of 6th Amendment right to counsel](https://6ac.org/state-of-new-york-to-provide-full-state-funding-of-6th-amendment-right-to-counsel/) - Pleading the Sixth: On June 17, 2016, the New York Assembly passed a bill requiring full state funding of indigent defense services, after the Senate passed the measure the previous night. Will Governor Cuomo sign it into law? On June 17, 2016, the New York State Assembly unanimously passed A10706 requiring the state to take
- [State public defense commission bill entered in Idaho legislature](https://6ac.org/state-public-defense-commission-bill-entered-in-idaho-legislature/) - Pleading the Sixth: A new bill creating a statewide public defense commission was entered into the Idaho House of Representatives in early February 2014. The bill is the recommendation of a legislative interim committee on public defense reform that studied systemic deficiencies in 2013. Importantly, the bill specifically bans the practice of flat fee contracting
- [Strike Four, now what? ACLU sues Kern County, California for systemically denying counsel](https://6ac.org/strike-four-now-what-aclu-sues-kern-county-california-for-systemically-denying-counsel/) - In a lawsuit filed against Kern County last week, the ACLU alleges constitutional violations at the arraignment where probation officers offer plea deals to unrepresented defendants and encourage them to waive counsel in a process that is closed to the public. If true, Kern County would be the fourth California county exposed for systemically denying
- [Support for a White House Commission on the public defense crisis mounts](https://6ac.org/panelists-from-doj-gideons-50th-event-propose-white-house-commission-on-public-defense-crisis/) - Pleading the Sixth: On March 15th, 2013 the U.S. Department of Justice hosted an event commemorating the 50th anniversary of Gideon v. Wainwright. The event was both a celebration of the watershed case’s promise of a meaningful right to counsel, and a somber discussion of the nation’s long-standing systemic deficiencies in realizing that promise. Not
- [Systemic right to counsel failures cannot be resolved in case-by-case reviews](https://6ac.org/systemic-right-to-counsel-failures-cannot-be-resolved-by-case-by-case-reviews/) - Pleading the Sixth: In America, the indigent accused has a constitutional right to be represented by an effective lawyer at all critical stages of a case where loss of liberty is a potential penalty. But what if that lawyer is incapable of, or structurally prevented from, advocating for a defendant's stated interests? Can the appellate courts
- [Tennessee Supreme Court backs major right to counsel reforms](https://6ac.org/tennessee-supreme-court-backs-major-right-to-counsel-reforms/) - Pleading the Sixth: The Tennessee Supreme Court released a press statement announcing its unanimous support for comprehensive indigent defense reforms, including the creation of a statewide indigent defense commission and a state appellate defender office, and the first increase in assigned counsel compensation rates in 20 years. Change is definitely afoot in yet another conservative
- [Tennessee Supreme Court Task Force recommends complete overhaul of right to counsel services](https://6ac.org/tennessee-supreme-court-task-force-recommends-complete-overhaul-of-right-to-counsel-services/) - Pleading the Sixth: Recognizing that the State of Tennessee needs a better way of providing right to counsel services, in September 2015 former Chief Justice Sharon Lee created an Indigent Representation Task Force and challenged them to “build a better mousetrap.” After 18 months of study and public hearings, the Task Force did just that. Today,
- [Tennessee undermines own values in providing counsel to the poor](https://6ac.org/tennessee-undermines-own-values-in-providing-counsel-to-the-poor/) - Pleading the Sixth: Tennessee has a grand tradition of holding almost every government function directly accountable to the electorate. However, a major structural flaw in how the state’s indigent defense budget is requested, defended and allocated between the state’s elected public defenders results in excessive caseloads and poor performance across the state. The 6AC exposes
- [Texas judges ask out of indigent defense oversight](https://6ac.org/texas-judges-ask-out-of-indigent-defense-oversight/) - Pleading the Sixth: In an effort to meet the American Bar Association’s Ten Principles, judges in Travis County, Texas (Austin) created a plan to remove themselves from the oversight and administration of public defense services. Will the proposed “managed assigned counsel” plan become a model for the rest of Texas? Recognizing that having judges oversee the payment
- [The "Indiana Model" for providing right to counsel services does not work](https://6ac.org/the-indiana-model-for-providing-right-to-counsel-services-does-not-work/) - Pleading the Sixth: On October 24, 2016, the Sixth Amendment Center released its report on trial level indigent defense services in Indiana. Beginning in the 1990s, the “Indiana Model” was widely promoted as potentially the best way to improve the provision of the right to counsel in states throughout America. This new report details the first
- [The clock runs out on Michigan reform for this year](https://6ac.org/the-clock-runs-out-on-michigan-reform-for-this-year/) - Pleading the Sixth: At 4:30 AM on December 14, 2012, time ran out for indigent defense reform in Michigan for this year, as HB 5804 was not able to make it through the Senate before the final bell of the legislative session. Undeterred, public defense reform advocates, including key legislative and criminal justice leaders, vow
- [The criminalization of poverty: a spotlight on South Dakota](https://6ac.org/the-criminalization-of-poverty-a-spotlight-on-south-dakota/) - Pleading the Sixth: When states make counties wholly responsible for the delivery of trial-level indigent defense services without state oversight of those services, bad things can and do happen. In this two-part report, the 6AC looks at South Dakota’s decentralized right to counsel system, and the resulting impact on the client community. Part I examines South
- [The Idaho Supreme Court says Strickland is “inapplicable” to remedying systemic indigent defense deficiencies; reinstates ACLU lawsuit](https://6ac.org/the-idaho-supreme-court-affirms-that-strickland-is-inapplicable-to-remedying-systemic-indigent-defense-deficiencies-reinstates-aclu-lawsuit/) - Pleading the Sixth: On April 28, 2017, the Idaho Supreme Court reinstated the ACLU lawsuit that alleges wide-ranging systemic deficiencies in the state’s provision of indigent defense services. Finding that the lower court erred in requiring defendants to suffer the actual harm of ineffective assistance of counsel and only then remedy the issues on a case-by-case
- [The State of Illinois defaults on its constitutional right to counsel obligation](https://6ac.org/the-state-of-illinois-defaults-on-its-constitutional-right-to-counsel-obligation/) - A new study shows there are two overarching reasons why the State of Illinois is defaulting on its constitutional right to counsel obligations. First, the state requires counties and courts to provide and predominantly fund indigent defense systems in a way that bakes in governmental interference with the right to counsel. Second, as one of
- [The United Nations takes the Ten Principles international](https://6ac.org/the-united-nations-takes-the-ten-principles-international/) - Pleading the Sixth: The United Nations General Assembly adopted new Principles and Guidelines for how member states should deliver indigent defense services. Drafted to help emerging nations grappling with equal justice concerns, the U.N. document can help us hold a mirror up to our own deficient indigent defense systems here at home, as many of
- [Timely access to counsel declared a national priority](https://6ac.org/timely-access-to-counsel-declared-a-national-priority/) - Pleading the Sixth: On March 2, 2023, the U.S. Department of Justice launched a national tour to commemorate the 60th Anniversary of Gideon v. Wainwright. A focus of the tour’s first stop was timely access to counsel for indigent defendants. Looking to Missouri’s recent court order in a class-action lawsuit that now requires a two-week
- [U.S. House unanimously passes resolution supporting the right to counsel](https://6ac.org/u-s-house-unanimously-passes-resolution-supporting-the-right-to-counsel/) - “The first step towards solving any problem is acknowledging one exists,” stated Congressman Ted Deutch (FL-21), speaking November 13, 2013, on the floor of the U.S. House of Representatives in support of House Resolution 196, Supporting the Sixth Amendment to the US Constitution, the right to counsel. The problem in question, according to Deutch, is that “the fundamental right of
- [U.S. Senator Leahy introduces Gideon’s Promise Act](https://6ac.org/u-s-senator-leahy-introduces-gideons-promise-act/) - Pleading the Sixth: In honor of the 50th anniversary of Gideon v. Wainwright, Sen. Patrick Leahy introduced a new bill – the Gideon’s Promise Act – to give the U.S. Department of Justice authorization to sue states, counties and attorneys that fail to uphold the Sixth Amendment right to counsel. Included in the bill is
- [Understanding the GAO Report on Indigent Defense](https://6ac.org/understanding-the-gao-report-on-indigent-defense/) - Pleading the Sixth: On May 9, 2012, the United States Government Accountability Office (GAO) released its report on the right to counsel in America. According to the GAO, only a very small percentage of federal funding dedicated to enhancing state criminal justice systems ever makes its way to the indigent defense function. GAO then concludes
- [US DOJ enters Statement of Interest in NYCLU class action lawsuit](https://6ac.org/us-doj-enters-statement-of-interest-in-nyclu-class-action-lawsuit/) - Pleading the Sixth: The U.S. Department of Justice entered a Statement of Interest in a class action lawsuit brought by the New York Civil Liberties Union alleging egregious Sixth Amendment violations in that state. Importantly, the Statement denotes DOJ’s position on the systemic deficiencies that result in constructive denial of counsel, including “severe lack of
- [US DOJ investigating St. Louis family courts](https://6ac.org/us-doj-investigating-st-louis-family-courts/) - Pleading the Sixth: Having reached an agreement with Shelby County, Tennessee to usher in major reforms of the county’s juvenile court system and the method for representing children in delinquency proceedings, the US Department of Justice announced in mid-November that it is now turning its attention to St. Louis, Missouri. Given the statewide structure of
- [Utah reforms indigent defense with first-ever state dollars for trial representation](https://6ac.org/utah-reforms-indigent-defense-with-first-ever-state-dollars-for-trial-representation/) - Pleading the Sixth: In these days of political strife and partisan antagonism, it is encouraging to see that government can still work and reach consensus for the benefit of the people, as demonstrated by the near unanimous passage of a comprehensive indigent defense reform bill in Utah. Part I of this report explains the new
- [Utah’s right to counsel deficiencies](https://6ac.org/utahs-right-to-counsel-deficiencies/) - Pleading the Sixth: On October 26, 2015, the Sixth Amendment Center released a report exposing Utah’s long-standing, deep-rooted indigent defense deficiencies, including no state oversight, prosecutors in charge of some local indigent defense budgets, excessive defender caseloads, and a prevalence of flat fee contracts. Perhaps most telling, more than 62% of all people facing a
- [Why our misdemeanor courts are filled with uncounselled defendants](https://6ac.org/why-our-misdemeanor-courts-are-filled-with-uncounselled-defendants/) - Pleading the Sixth: On the eve of Senate Judiciary Committee hearings on the denial of counsel in our nation’s lower courts, here are four reasons people accused of misdemeanors go to jail everyday without speaking to a lawyer, and four reasons no one is doing anything about it. Under the U.S. Constitution, governments are barred
- [Why the State of California is responsible for the public defense crisis in Fresno County](https://6ac.org/why-the-state-of-california-is-responsible-for-the-public-defense-crisis-in-fresno-county/) - Pleading the Sixth: In late September 2013, more than 80% of the public defenders in Fresno County, California signed a letter protesting their working conditions, and in particular their excessive caseloads. Though some counties in California are rightfully recognized for their “best practice” approach to indigent defense services, the 6AC explores how the failure of
- [Why the State of Texas is responsible for denying counsel to indigent people in Amarillo](https://6ac.org/why-the-state-of-texas-is-responsible-for-denying-counsel-to-indigent-people-in-amarillo/) - Pleading the Sixth: More than 74% of all misdemeanor defendants in Potter County, Texas (Amarillo) face the possibility of jail time without the aid of a lawyer, due to sheriff’s deputies, county prosecutors, and trial court judges exerting direct, overt pressure on indigent defendants to forego exercising their constitutional right to counsel. A new 6AC
- [Will the Virgin Islands finally end the practice of conscripting non-qualified lawyers to represent the indigent accused?](https://6ac.org/will-the-virgin-islands-finally-end-the-practice-of-conscripting-non-qualified-lawyers-to-represent-the-indigent-accused/) - Pleading the Sixth: Although the Virgin Islands has a territorial public defender office, trial court administrative rules historically authorized judges to conscript any attorney barred in the territory – divorce lawyers and real estate lawyers included – to provide representation to the indigent accused in conflict cases. The Virgin Islands Supreme Court ordered an end
- [Williamson County TX settles “no counsel court” lawsuit](https://6ac.org/williamson-county-tx-settles-no-counsel-court-lawsuit/) - Pleading the Sixth: Williamson County, Texas settled a class action lawsuit alleging that judges engaged in a “systematic and deliberate scheme” to deprive “persons accused of misdemeanor offenses of their right to be represented by counsel.” By agreeing to set up systemic assurances that appointment procedures will be transparent and that defendants will no longer
- [Wisconsin Supreme Court increases compensation to some, but not all, indigent defense attorneys](https://6ac.org/wisconsin-supreme-court-increases-compensation-to-some-but-not-all-indigent-defense-attorneys/) - Pleading the Sixth: On June 27, 2018, the Supreme Court of Wisconsin ordered the compensation paid by counties to assigned counsel appointed by the courts raised from $70/hour to $100/hour beginning in January 2020, while the compensation paid by the state to private attorneys assigned by the Wisconsin State Public Defender remains at $40/hour or an
- [Wisconsin’s low attorney compensation rates create conflicts for the indigent accused](https://6ac.org/wisconsins-low-attorney-compensation-rates-create-conflicts-for-the-indigent-accused/) - Pleading the Sixth: Imagine holding the same job for 30 years without ever once receiving a raise. If that job required you to pay for many of the associated costs of doing business, inflation alone would have significantly decreased your take home pay. Regardless of the profession, the quality of the work being performed under
- [Withholding felony representation for months at a time in Mississippi](https://6ac.org/withholding-felony-representation-for-months-at-a-time-in-mississippi/) - Pleading the Sixth: Felony defendants throughout Mississippi are arrested and then routinely wait from typically two months to up to a year before a lawyer begins working on their behalf. When a felony lawyer is finally appointed, the attorney is too often under-resourced, overworked, and financially conflicted between working on behalf of the defendant’s legal interests
- [Wyoming public defender budget woes intensifying with increase in capital cases](https://6ac.org/wyoming-public-defender-budget-woes-intensifying-with-increase-in-capital-cases/) - Pleading the Sixth: The cost of providing competent death penalty representation is expensive due in no small part to the additional Sixth Amendment responsibilities placed on states by the U.S. Supreme Court. Because of this, even well-structured right to counsel systems will falter when the projected number of capital cases increases seven-fold, as is occurring
- [Lake County Report is the third strike against California’s deficient indigent defense systems](https://6ac.org/lake-county-report-is-the-third-strike-against-californias-deficient-indigent-defense-systems/) - Are indigent defense services best funded and coordinated by the government at the state level or local level? California has avoided answering this question for decades. Yet, a new 6AC report on Lake County, coupled with a prior 6AC report on Santa Cruz County and the ACLU lawsuit in Fresno County, show that ignoring this
- [Strike 5: The State of California calls a strike on San Benito County](https://6ac.org/strike-5-the-state-of-california-calls-a-strike-on-san-benito-county/) - Pleading the Sixth. The State of California calls a strike on itself in a new state report that finds “there are signs that effective representation is not being provided” in San Benito County. Since 2020, constitutional right to counsel deprivations have been exposed in Fresno, Santa Cruz, Lake, and Kern counties. How many more county
- [The State of the Nation on Gideon’s 60th Anniversary](https://6ac.org/the-state-of-the-nation-on-gideons-60th-anniversary/) - Pleading the Sixth: The fear of government unduly taking away one’s liberty led the United States Supreme Court to unanimously declare it an “obvious truth” that no indigent person can be assured a fair trial against the “machinery” of law enforcement without a lawyer. “The right of one charged with crime to counsel may not
- [Strike 6: New lawsuit hits in San Mateo County, California](https://6ac.org/strike-6-new-lawsuit-hits-in-san-mateo-county-california/) - Pleading the Sixth: For years, the San Mateo County Private Defender Program has been touted as one of the best in California. But several reports over the years and a new lawsuit filed in March call that claim into question, highlighting the program’s persistent problem in complying with national and state standards. If what is
- [Oregon passes sweeping indigent defense reforms](https://6ac.org/oregon-passes-sweeping-indigent-defense-reforms/) - Pleading the Sixth: On July 13, 2023, Governor Tina Kotek signed sweeping legislation into law that overhauls right to counsel services in Oregon. The new law adopts many of 6AC’s recommendations from its 2019 study: it abolishes flat fee contracting in favor of a hybrid staff public defender and private assigned counsel system, and it
- [New Guam report finds judicial influence over indigent defense](https://6ac.org/guam-report-finds-undue-judicial-influence-over-indigent-defense/) - Pleading the Sixth: Guam’s indigent defense system is not independent from the judiciary, impacting the provision of the right to effective assistance of counsel on the island. A new 6AC evaluation explains those impacts while recommending that Guam establish an independent commission with full authority to oversee right to counsel services. Guam’s justice system is
- [The devolution of the right to counsel in Wayne County, Michigan (Detroit)](https://6ac.org/the-devolution-of-the-right-to-counsel-in-wayne-county-michigan-detroit/) - Pleading the Sixth: A public defender office handling felony representation in Detroit was flat funded for 16 years. This despite a critical national report, an ACLU lawsuit, and comprehensive statutory reform, all intended to ensure effective representation of the indigent accused throughout Michigan. To say that this public defender office experienced flat funding, however, is a
- [New ACLU lawsuit: Washington State fails to ensure effective delinquency representation](https://6ac.org/new-aclu-lawsuit-washington-state-fails-to-ensure-effective-delinquency-representation/) - Pleading the Sixth: In a new lawsuit, the ACLU of Washington alleges that the right to counsel system for juveniles facing delinquency proceedings in Grays Harbor is so constitutionally deficient that the State of Washington must take action. On April 3, 2017, the American Civil Liberties Union of Washington (ACLU-WA) filed a class action lawsuit
- [Actual denial of counsel & government tyranny](https://6ac.org/actual-denial-of-counsel-government-tyranny/) - Pleading the Sixth: On May 13, 2015, the U.S. Senate Judiciary Committee held a first-ever hearing on the failure of state, county and local courts to appoint lawyers to the indigent accused, as is their Constitutional duty. As the 6AC thanks Senator Grassley for his continued leadership for calling America’s attention to the hundreds of
- [USDOJ calls for binding workload controls as part of resolution to federal suit against two Washington cities](https://6ac.org/usdoj-calls-for-binding-workload-controls-as-part-of-resolution-to-federal-suit-against-two-washington-cities/) - Pleading the Sixth: A class action lawsuit pending before a federal court in Seattle, Washington, alleges the cities of Mt. Vernon and Burlington systematically deprive defendants facing criminal prosecution in the cities’ municipal courts of the right to the effective assistance of counsel. While the judge presiding considers the merits of the allegations presented at
- [Florida Supreme Court grants public defenders the right to declare case overload](https://6ac.org/florida-supreme-court-grants-public-defenders-the-right-to-declare-case-overload/) - Pleading the Sixth: On May 23, 2013, the Florida Supreme Court granted the 11th Circuit Public Defender (Miami-Dade County) the right to refuse new cases due to case overload. Importantly, the Court makes the case that Strickland is an inadequate remedy to right to counsel violations resulting from excessive caseloads. Any attempt to deal with
- [Podcast: A conversation about the 6AC report on the right to counsel in rural Nevada, Reclaiming Justice](https://6ac.org/podcast-a-conversation-about-the-6ac-report-on-the-right-to-counsel-in-rural-nevada-reclaiming-justice/) - Today, we recorded an 8-minute conversation with David Carroll, executive director with the Sixth Amendment Center, getting a little bit of the backstory on Reclaiming Justice, our report on the right to counsel in rural Nevada. Listen to the conversation here.
- [Nevada Justice calls for state to fix rural right to counsel services](https://6ac.org/nevada-justice-calls-for-state-to-fix-rural-right-to-counsel-services/) - Pleading the Sixth: “Nevada’s rural counties simply cannot shoulder the state’s obligations under the Sixth Amendment of the U.S. Constitution any longer,” announced Nevada Supreme Court Justice Michael Cherry in an official Court press release announcing the publication of the 6AC report Reclaiming Justice. The report details Nevada’s first-in-the-nation status of requiring the appointment and
- [Louisiana Governor institutionalizes political interference](https://6ac.org/louisiana-governor-institutionalizes-political-interference/) - Pleading the Sixth: This week, Louisiana Governor Jeff Landry transferred the responsibility of indigent defense from an eleven-member state oversight board to a single governor appointee. Decisions about employment, contracting, salaries, and funding are now under the purview of a single individual and subject to review by a newly created advisory board only under very
- [South Dakota leaves nation’s “no state funding” list in groundbreaking legislation](https://6ac.org/south-dakota-leaves-nations-no-state-funding-list-in-groundbreaking-legislation/) - Pleading the Sixth: On Gideon Day, March 18, South Dakota’s Governor signed groundbreaking legislation creating a state commission with authority to oversee right to counsel services statewide with overwhelming support from all three branches of state government and various stakeholders. The nation can now celebrate that, for the first time in its history, every state contributes some amount of
- [6AC's David Carroll appears on the OpenMike podcast](https://6ac.org/6acs-david-carroll-appears-on-the-openmike-podcast/) - In a conversation ranging from national issues on right to counsel reforms, to Michigan's continuing progress toward constitutional compliance, to the experiences of Wayne County (Detroit) establishing a new public defender system in response to a 6AC study finding significant systemic deficiencies, 6AC executive director David Carroll was a guest on the OpenMike podcast, hosted
- [Attorney General Eric Holder calls for criminal justice overhaul](https://6ac.org/attorney-general-eric-holder-calls-for-criminal-justice-overhaul/) - Pleading the Sixth: On December 11, 2012, U.S. Attorney General Eric Holder reaffirmed our country’s Sixth Amendment “crisis” and called for a bi-partisan reevaluation “about how we do criminal justice in the United States.” “Are we putting in jail the appropriate people? Are we putting people in jail for appropriate lengths of time? Are we putting
- [Last Week Tonight tackles indigent defense crisis](https://6ac.org/last-week-tonight-tackles-indigent-defense-crisis/) - The 6AC was proud to help the folks at Last Week Tonight with John Oliver over the past couple of weeks as they developed an in-depth segment on the nationwide indigent defense crisis. Watch it here. https://youtu.be/USkEzLuzmZ4
- [Conference of Chief Justices endorses proposed National Center for the Right to Counsel](https://6ac.org/conference-of-chief-justices-endorses-proposed-national-center-for-the-right-to-counsel/) - Pleading the Sixth: With a resolution adopted at its 2014 Annual Meeting, the Conference of Chief Justices (CCJ) and the Conference of State Court Administrators (COSCA) together have endorsed the proposed legislation to create a National Center for the Right to Counsel, as introduced in October 2013 by Congressman Ted Deutch (FL-21). “NOW, THEREFORE, BE
- [A reason for optimism for the right to counsel in Utah and lessons for achieving the best paradigm of justice everywhere](https://6ac.org/a-reason-for-optimism-for-the-right-to-counsel-in-utah-and-lessons-for-achieving-the-best-paradigm-of-justice-everywhere/) - Pleading the Sixth: In these days of political strife and partisan antagonism, it is encouraging to see that government can still work and reach consensus for the benefit of the people, as demonstrated by the near unanimous passage of a comprehensive indigent defense reform bill in Utah. Here the 6AC explains the historical underpinnings of
- [Nevada establishes statewide right to counsel commission](https://6ac.org/nevada-establishes-statewide-right-to-counsel-commission/) - Pleading the Sixth: The Nevada Governor signed into law a bill creating a statewide indigent defense commission. Following the example from Idaho’s recent reforms, the new law funds the commission to hire staff, collect data, evaluate current services, and make legislative recommendations to ensure that the state’s obligations under the 6th and 14th Amendments are met
- [Missouri prosecutors blame public defenders leadership for “broken system”](https://6ac.org/missouri-prosecutors-blame-public-defenders-leadership-for-broken-system/) - Pleading the Sixth: The Missouri Association of Prosecuting Attorneys (MAPA) have placed opinion pieces in several leading newspapers admitting that the indigent defense system is broken but blaming the crisis on a lack of public defender leadership. The Sixth Amendment Center again takes issue with MAPA’s interpretation of the facts countering with our own opinion
- [Maryland Supreme Court orders attorneys at bail hearings](https://6ac.org/maryland-supreme-court-orders-attorneys-at-bail-hearings/) - Pleading the Sixth: On September 25, 2013, the Maryland Supreme Court reaffirmed its earlier holding that the right to counsel applies to all bail hearings before a commissioner. In effect, this undoes legislative attempts - created in the wake of an earlier ruling - to hold down indigent defense costs by only providing counsel at bail
- [Closing Arguments with Dennis Keefe](https://6ac.org/closing-arguments-with-dennis-keefe/) - “Closing Arguments” is a joint venture of the National Association for Public Defense (NAPD) and the Sixth Amendment Center (6AC). The 6AC will regularly sit down with long-time right to counsel leaders nearing the end of their careers to share thoughts and to pass on lessons learned to the next generation. Our first interview is with
- [Closing Arguments with Fred Friedman](https://6ac.org/closing-arguments-with-fred-friedman/) - “Closing Arguments” is a joint venture of the National Association for Public Defense (NAPD) and the Sixth Amendment Center (6AC). The 6AC regularly sits down with long-time right to counsel leaders nearing the end of their careers to share thoughts and to pass on lessons learned to the next generation. Today, we sit down with Fred
- [Low attorney pay in New York: a cautionary tale for the country](https://6ac.org/low-attorney-pay-in-new-york-a-cautionary-tale-for-the-country/) - Assigned attorneys in most of New York State have not received a raise since 2004, when the legislature set the compensation rate at $60 to $75 per hour. The consequence? A “crisis” in assigned counsel programs, at least three pending lawsuits, and a threat to the Sixth Amendment. Assigned attorneys in most of New York
- [Virginia legislative report finds low fee caps cause problems](https://6ac.org/virginia-legislative-report-finds-low-fee-caps-cause-problems/) - Pleading the Sixth: A recent legislative report in Virginia finds that the low fee caps imposed on private court-appointed attorneys result in a decline in the number of attorneys willing to take court-appointed cases and the quality of representation by those who remain. This is the third report in 20 years – and the first

## Pages

- [Home](https://6ac.org/) - 6AC works to ensure that no person accused of crime goes to jail without having the aid of an effective lawyer, as guaranteed by the US Constitution.
- [State of the Sixth](https://6ac.org/state-of-the-sixth/) - People want to know how the right to counsel is implemented in their state, county, or territory. Some want to know how this all works someplace else. We give you all the tools you need in this interactive map to explore. Once you have the basics down, dig deeper by expanding on our state-specific questions.
- [Careers](https://6ac.org/who-we-are/careers/)
- [Qualifying for the Sixth](https://6ac.org/qualifying-for-the-sixth/) - How poor must someone be to qualify for a public defender? “Qualifying for the Sixth” offers state policymakers practical guidance for establishing fair, efficient, and fiscally responsible rules for determining indigency in adult trial-level criminal cases.
- [Our Law Student Network](https://6ac.org/who-we-are/law-student-network/) - Passionate about public defense and the right to counsel? Gain hands-on experience in criminal justice policy with a paid, hybrid Summer 2026 law student internship. Apply today!
- [Internship Application](https://6ac.org/internship-application/)
- [Discovery](https://6ac.org/discovery/) - Whether you’re new to indigent defense or have been steeped in the field for decades, understanding the right to counsel is difficult because the law is complex and evolves. Moreover, states try to actualize that law in many ways. Pick out a book from our shelf and flip it open to understand these concepts in an easily digestible format. Contact us with ideas for other books on topics you are interested in!
- [History of the Sixth](https://6ac.org/history-of-the-sixth/) - Trace the history of the right to counsel in your jurisdiction.
- [Ask Us](https://6ac.org/ask-us/) - Wherever you are writing from, and whoever you are — a policymaker, journalist, criminal justice stakeholder, professor, student, concerned constituent, or someone who just wants to talk about the right to counsel — we want to hear from you. 617-927-9817Ext. 803: Media InquiriesExt. 804: Technical Assistance Inquiries
- [Paying Attorneys of the Sixth](https://6ac.org/paying-attorneys-of-the-sixth/) - We get asked a lot of questions about attorney pay: how much should government pay private attorneys for providing public defense services? What are the private attorney hourly rates in every state? Should government avoid certain payment methods? “Paying Attorneys of the Sixth” gives you the hourly rate for every case type in every jurisdiction in America and the answers to these questions.
- [Our Staff](https://6ac.org/who-we-are/our-staff/)
- [Hows of the Sixth](https://6ac.org/the-hows-of-the-sixth/)
- [ABCs of the Sixth](https://6ac.org/the-abcs-of-the-sixth/)
- [Who We Are](https://6ac.org/who-we-are/) - The Sixth Amendment Center was founded in 2013 to help policymakers provide the right to counsel, a core American value that pre-dates the founding of our country. Because we can all agree that government should not take away a person’s liberty simply because it has the power to, our board and staff reflect all ends of the political spectrum. Meet the team that can help your jurisdiction.
- [Counsel at All Critical Stages of a Delinquency Proceeding](https://6ac.org/counsel-at-all-critical-stages-of-a-delinquency-proceeding/) - Children charged in juvenile proceedings where they face incarceration as a possible penalty, and who cannot afford to hire their own lawyer, are constitutionally entitled to public counsel.[1] Indiana law goes further and requires a court to appoint counsel for any child alleged to have committed a delinquent act who does not have an attorney
- [2014 Caseload Assignments for All Attorneys in Marion County](https://6ac.org/2014-caseload-assignments-for-all-attorneys-in-marion-county/) - The Marion County Public Defender Agency employs (or has openings for) at least 160 attorneys (including certified interns, but not including conflict attorneys) who represent indigent clients. It reports the caseloads for these attorneys to the Commission broken down by divisions of the public defender office. The office employs (or has openings for) at least
- [2014 Caseload Assignments for Criminal Division Attorneys in Lake County](https://6ac.org/2014-caseload-assignments-for-criminal-division-attorneys-in-lake-county/) - Only the criminal division of the Lake County Superior Court participates in the Commission non-capital indigent expense reimbursement program, so Lake County's reports to the Commission are only for the four courts in the criminal division. Lake County reports all of its criminal division attorneys as having adequate support staff. The total 46 trial attorneys
- [2014 Caseload Assignments for County & Juvenile Division Attorneys in Lake County](https://6ac.org/2014-caseload-assignments-for-county-juvenile-division-attorneys-in-lake-county/) - The county division and juvenile division of the Lake County Superior Court do not participate in the Commission non-capital indigent expense reimbursement program, so Lake County does not report information about them to the Commission. Lake County did not make its caseload assignments available for these courts. To estimate the caseloads of the individual attorneys,
- [2014 Caseload Assignments for All Attorneys in Elkhart County](https://6ac.org/2014-caseload-assignments-for-all-attorneys-in-elkhart-county/) - Elkhart County did not initially make its caseload assignments available. In June 2016, the Elkhart County Public Defender Office provided to 6AC information about the number of cases assigned in each courtroom for the period of December 11, 2014 through December 11, 2015. Because the information provided does not allow for an apples-to-apples comparison with
- [2014 Caseload Assignments for All Attorneys in Warrick County](https://6ac.org/2014-caseload-assignments-for-all-attorneys-in-warrick-county/) - Only two of the four Warrick County judges made their caseload assignments available, and one judge had just taken the bench so could not provide caseload assignments for 2014. To estimate the caseloads of the individual attorneys, 6AC relied on publicly available data from the Indiana Judicial Service Report for 2014 for the numbers of
- [2014 Caseload Assignments for All Attorneys in Lawrence County](https://6ac.org/2014-caseload-assignments-for-all-attorneys-in-lawrence-county/) - Click on the image to view in full.
- [2014 Caseload Assignments for All Attorneys in Montgomery County](https://6ac.org/2014-caseload-assignments-for-all-attorneys-in-montgomery-county/) - While participating in the IPDC, Montgomery County was allowed to report its contract attorneys as full-time with inadequate support staff and, based on whatever percentage the attorney's compensation was of the highest paid deputy prosecutor in the county, was allowed to assign them up to that same percentage of a full-time caseload. (See * in
- [2014 Caseload Assignments for All Attorneys in Scott County](https://6ac.org/2014-caseload-assignments-for-all-attorneys-in-scott-county/) - The attorneys who contract to provide representation in circuit and superior courts (noted by * in the table below) are all required to accept up to three conflict-based CHINS/TPR cases each year. Beyond that, they can be appointed on a case-by-case basis and compensated hourly. There are likely additional individual attorneys who were appointed directly by
- [2014 Caseload Assignments for All Attorneys in Blackford County](https://6ac.org/2014-caseload-assignments-for-all-attorneys-in-blackford-county/) - In reports to the IPDC, Blackford County reports two of its assigned attorneys as full-time with inadequate support staff (noted by * in the table below). None of the assigned attorneys in Blackford County are full-time. They all have private law offices, and they all receive the same hourly compensation for their appointed work. Click
- [Indigent Defense Services in the Sample Counties](https://6ac.org/indigent-defense-services-in-the-sample-counties/) - The Indiana General Assembly by statute defines the conduct that will constitute a crime or a delinquent act, the procedures that must be followed throughout the life of that criminal or juvenile case, and the penalties that may be imposed on a person who is convicted.[1] The same is true for the conduct that will
- [Commission Members to Do the Work of the Commission](https://6ac.org/commission-members-to-do-the-work-of-the-commission/) - Click on image to view in full.
- [Staff to Do the Work of the Commission](https://6ac.org/staff-to-do-the-work-of-the-commission/) - The Commission has significant time-consuming statutory responsibilities. It has on-going responsibility to recommend standards for all indigent defense services. It is wholly responsible for establishing and overseeing the procedures that counties must follow to seek and receive both capital and non-capital reimbursement. And, it is responsible for carrying out on a continuing basis the state
- [IPDC Quarterly Reimbursement Request forms](https://6ac.org/ipdc-quarterly-reimbursement-request-forms/) - Click on any image to enlarge. 1 - Request for Reimbursement form 2 - Attorney Qualifications form 3 - Verifications 4 - Case Assignment Worksheet, D-Felony only, FT, adequate support staff 5 - Case Assignment Worksheet, D-Felony only, FT, inadequate support staff 6 - Case Assignment Worksheet, D-Felony only, PT, adequate support staff 7 -
- [IPDC, sample Comprehensive Plans and Model Ordinance](https://6ac.org/ipdc-sample-comprehensive-plans-and-model-ordinance/) - Click image to view full document.
- [Capital Reimbursement by IPDC, 1990 to 2014](https://6ac.org/capital-reimbursement-by-ipdc-1990-to-2014/) - Since July 1, 1989, all of Indiana's 92 counties have been eligible for reimbursement by the state for 50% of their defense costs in death penalty cases where the defendant is indigent and receives publicly provided counsel. The Indiana Public Defender Commission administers the reimbursement program and is responsible only for verifying that the expenses
- [Non-Capital Reimbursement by IPDC, 1995-2014](https://6ac.org/non-capital-reimbursement-by-ipdc-1995-2014/) - The information provided in the table below was compiled by the Sixth Amendment Center from a review of the Minutes of all meetings of the Indiana Public Defender Commission from January 29, 1998 through September 17, 2014. The Commission operates on a fiscal year running from July 1 through June 30, while the counties operate on
- [Expert Services](https://6ac.org/what-we-do/expert-services/) - We provide technical assistance that is tailored to the unique needs and requests in each jurisdiction. This ranges from staffing government task forces, to holding confidential one-on-one meetings, to testifying before legislatures when asked. We also educate the public through speaking engagements, our Pleading the Sixth blog, and sharing what we know about the right to counsel so you can help fix the issue.
- [Support Our Work](https://6ac.org/donate/) - Investing in us is investing in sustainable criminal justice reform.
- [Our Board](https://6ac.org/who-we-are/our-board/)
- [What We Do](https://6ac.org/what-we-do/) - We offer expert support to federal, state, and local policymakers and stakeholders who want to improve their indigent defense services. We share objective information and a national perspective on what works and does not work. We trust that the legislative process results in constitutional services that meet the unique needs of a jurisdiction.
- [Evaluations](https://6ac.org/what-we-do/evaluations/) - We independently and objectively evaluate indigent defense systems using Sixth Amendment case law, local and federal laws, and national standards as our guides. We do so only when asked by the jurisdiction. Our methodology includes legal research and analysis; data collection and analysis; court observations; and interviews with criminal justice stakeholders and policymakers.
- [Search](https://6ac.org/search/)
- [Conflict Cases in Lawrence County](https://6ac.org/conflict-cases-in-lawrence-county/) - The Lawrence County public defender office, with its six full-time attorneys and two office staff, handles near all conflict cases including those involving codefendants. “We cover as many conflicts as we can in-house,” the office explained. In a multi-defendant case, each codefendant is assigned to a different public defender office attorney until the office runs

## US Territories

- [Montana](https://6ac.org/us-territory/montana/)
- [Illinois](https://6ac.org/us-territory/illinois/)
- [Maryland](https://6ac.org/us-territory/maryland/)
- [Iowa](https://6ac.org/us-territory/iowa/)
- [New York](https://6ac.org/us-territory/new-york/)
- [Wyoming](https://6ac.org/us-territory/wyoming/)
- [Maine](https://6ac.org/us-territory/maine/)
- [Louisiana](https://6ac.org/us-territory/louisiana/)
- [Kentucky](https://6ac.org/us-territory/kentucky/)
- [Kansas](https://6ac.org/us-territory/kansas/)
- [Indiana](https://6ac.org/us-territory/indiana/)
- [Idaho](https://6ac.org/us-territory/idaho/)
- [Hawai'i](https://6ac.org/us-territory/hawaii/)
- [Alabama](https://6ac.org/us-territory/alabama/)
- [Arizona](https://6ac.org/us-territory/arizona/)
- [Arkansas](https://6ac.org/us-territory/arkansas/)
- [California](https://6ac.org/us-territory/california/)
- [Colorado](https://6ac.org/us-territory/colorado/)
- [Connecticut](https://6ac.org/us-territory/connecticut/)
- [Delaware](https://6ac.org/us-territory/delaware/)
- [Florida](https://6ac.org/us-territory/florida/)
- [Alaska](https://6ac.org/us-territory/alaska/)
- [Georgia](https://6ac.org/us-territory/georgia/)
- [Massachusetts](https://6ac.org/us-territory/massachusetts/)
- [Michigan](https://6ac.org/us-territory/michigan/)
- [Minnesota](https://6ac.org/us-territory/minnesota/)
- [Mississippi](https://6ac.org/us-territory/mississippi/)
- [Missouri](https://6ac.org/us-territory/missouri/)
- [Nebraska](https://6ac.org/us-territory/nebraska/)
- [Nevada](https://6ac.org/us-territory/nevada/)
- [New Hampshire](https://6ac.org/us-territory/new-hampshire/)
- [South Carolina](https://6ac.org/us-territory/south-carolina/)
- [Rhode Island](https://6ac.org/us-territory/rhode-island/)
- [Pennsylvania](https://6ac.org/us-territory/pennsylvania/)
- [Oregon](https://6ac.org/us-territory/oregon/)
- [Oklahoma](https://6ac.org/us-territory/oklahoma/)
- [Ohio](https://6ac.org/us-territory/ohio/)
- [North Dakota](https://6ac.org/us-territory/north-dakota/)
- [North Carolina](https://6ac.org/us-territory/north-carolina/)
- [New Mexico](https://6ac.org/us-territory/new-mexico/)
- [New Jersey](https://6ac.org/us-territory/new-jersey/)
- [Wisconsin](https://6ac.org/us-territory/wisconsin/)
- [Puerto Rico](https://6ac.org/us-territory/puerto-rico/)
- [Northern Mariana Islands](https://6ac.org/us-territory/northern-mariana-islands/)
- [Guam](https://6ac.org/us-territory/guam/)
- [American Samoa](https://6ac.org/us-territory/american-samoa/)
- [District of Columbia](https://6ac.org/us-territory/district-of-columbia/)
- [West Virginia](https://6ac.org/us-territory/west-virginia/)
- [Washington](https://6ac.org/us-territory/washington/)
- [Virginia](https://6ac.org/us-territory/virginia/)
- [Vermont](https://6ac.org/us-territory/vermont/)
- [Utah](https://6ac.org/us-territory/utah/)
- [Texas](https://6ac.org/us-territory/texas/)
- [Tennessee](https://6ac.org/us-territory/tennessee/)
- [South Dakota](https://6ac.org/us-territory/south-dakota/)
- [US Virgin Islands](https://6ac.org/us-territory/us-virgin-islands/)

## ABC Cards

- [In which type of cases does the right to counsel apply?](https://6ac.org/abc-card/in-which-type-of-prosecutions-does-the-right-to-counsel-apply/) - A criminal case that carries any amount of incarceration as a possible sentence. Both adults and children are guaranteed the right to appointed counsel in these cases, and it does not matter whether the government defines the charged offense as a felony or a misdemeanor or a delinquency or calls it something else entirely. An
- [In what courts must government appoint counsel?](https://6ac.org/abc-card/in-what-courts-must-government-appoint-counsel/) - In any court where a person faces the “potential loss of liberty in a criminal prosecution” – a criminal offense in which a person can, at any point be sentenced to serve any time in jail or prison.
- [Can there be a critical stage without a person having a lawyer?](https://6ac.org/abc-card/can-there-be-a-critical-stage-without-a-person-having-a-lawyer/) - No, unless the defendant enters a knowing, voluntary, and intelligent waiver of the right to counsel. A judge must be “rigorous” in ensuring that a person has the requisite knowledge to make an informed decision about waiving the right to counsel, including understanding the nature of the charge and the stage of the proceeding. A person’s
- [Can a prosecutor negotiate a plea with an unrepresented person?](https://6ac.org/abc-card/can-a-prosecutor-negotiate-a-plea-with-an-unrepresented-person/) - No. Plea negotiations are a critical stage in a case. A prosecutor can only negotiate directly with an unrepresented person if, first, the court obtains a valid waiver of counsel.
- [How do states determine whether a person is indigent?](https://6ac.org/abc-card/how-do-states-define-and-determine-whether-a-person-is-indigent/) - States use a wide variety of methods for determining indigency. Most states use objective criteria and presume indigence in certain situations (e.g., receiving public assistance, being in custody, living in a treatment facility, being a “juvenile,” or having an income below a set percentage of the Federal Poverty Guidelines), and require individualized financial inquiries only
- [What does “indigent” mean?](https://6ac.org/abc-card/what-does-indigent-mean/) - “Indigent” means “of insufficient means.” In the context of the Sixth Amendment right to counsel, “indigent” is a description of a person who does not have sufficient income or assets to afford the prevailing rate of a private criminal defense attorney in their jurisdiction without substantial burden or undue hardship (e.g., depriving themselves or their family
- [Does the Sixth Amendment right to counsel apply in U.S. territories?](https://6ac.org/abc-card/does-the-sixth-amendment-right-to-counsel-apply-in-u-s-territories/) - In some territories, but not all. U.S. Congress has the authority to determine whether and which constitutional rights apply in the territories. Currently, the Sixth Amendment right to counsel applies in Guam, Northern Mariana Islands and U.S. Virgin Islands, but it does not apply in American Samoa and Puerto Rico.
- [Can a state provide the right to counsel in non-criminal cases?](https://6ac.org/abc-card/can-a-state-provide-the-right-to-counsel-in-non-criminal-cases/) - Yes. The U.S. Supreme Court recognizes that a state is “free to provide greater protections in their criminal justice system than the Federal Constitution requires,” but it cannot provide less. Although the U.S. Constitution has not been held to require it, some states appoint counsel to represent people in post-conviction cases, termination of parental rights
- [Can a state pass its right to counsel obligations onto local government?](https://6ac.org/abc-card/can-a-state-pass-its-right-to-counsel-obligations-onto-local-government/) - The U.S. Supreme Court has never been asked whether it is constitutional for state government to pass its right to counsel obligations onto its local governments. However, when a state chooses to delegate its right to counsel responsibilities to local government, the state must guarantee that those local governments can and are providing effective representation.
- [Why is the right to counsel a state government obligation?](https://6ac.org/abc-card/why-is-the-right-to-counsel-a-state-government-obligation/) - The U.S. Supreme Court holds that ensuring the Sixth Amendment right to counsel is a state – not local – obligation under the Fourteenth Amendment. American Bar Association standards also reflect this, stating in part: “since the responsibility to provide defense services rests with the state, there should be … a statewide structure responsible for
- [What kind of system can ensure an effective lawyer?](https://6ac.org/abc-card/how-does-the-court-determine-whether-a-lawyer-is-effective/) - Policymakers must ensure that their state’s indigent defense system is effective, so they want to know how best to design systems that will deliver effective indigent defense services. Under United States v. Cronic, an effective system is one that appoints qualified and trained attorneys early in the case who have sufficient time and resources to
- [What level of performance must an appointed lawyer provide to a person?](https://6ac.org/abc-card/what-type-of-counsel-must-the-government-provide/) - A lawyer must be “effective.” The U.S. Supreme Court defines an “effective” lawyer as a lawyer whose performance was reasonable under prevailing professional norms and standards, such as American Bar Association standards.
- [What is a “critical stage” in a case?](https://6ac.org/abc-card/what-is-a-critical-stage-in-a-case/) - There are certain stages in a case – whether formal or informal, in court or out of court – that are “critical” because of what is at stake for the defendant and the adversarial nature of the stage. The U.S. Supreme Court has not created an exhaustive list of critical stages, though there are many,
- [When during the criminal case must government provide a lawyer?](https://6ac.org/abc-card/when-during-the-criminal-case-must-government-provide-a-lawyer/) - The U.S. Supreme Court states that the right to counsel attaches at a person’s first appearance before a judicial officer, where they learn of the charge against them and their liberty is subject to restriction. However, the Constitution does not require that a lawyer be present at this moment, but from this moment forward, no
- [Are local municipal courts required to appoint counsel?](https://6ac.org/abc-card/are-local-municipal-courts-required-to-appoint-counsel/) - The name or level of the court in which a defendant is charged does not change the constitutional requirements of the right to counsel. For example, an indigent person charged in a municipal court for violating a municipal ordinance that has a possible penalty of a fine and/or up to 30 days in jail is
- [Can people be required to repay the cost of their appointed representation?](https://6ac.org/abc-card/can-people-be-required-to-repay-the-cost-of-their-appointed-representation/) - Only in limited circumstances. The U.S. Supreme Court states that the government may ask for repayment only if (1) a person has the ability to pay and (2) if the government has in place certain procedural safeguards, such as providing a person the opportunity at any time to show that repayment will impose manifest hardship to
- [Are there national standards on defining and determining a person’s indigency?](https://6ac.org/abc-card/are-there-national-standards-on-defining-and-determining-a-persons-indigency/) - Yes. American Bar Association standards recommend that all people in custody or receiving public assistance should be presumed indigent “absent contrary evidence.” For all people, courts should appoint a lawyer to anyone who cannot “obtain adequate representation without substantial burden or undue hardship.” Any screening process should be confidential and uncomplicated.
- [Is there one definition for “indigent” that all states use?](https://6ac.org/abc-card/is-there-one-definition-for-indigent-that-all-states-use/) - No. The U.S. Supreme Court has left it to the states to define the term “indigent." That said, the Court has stated, “An impoverished accused is not necessarily one totally devoid of means. . . . the fact that a defendant may be able to muster enough resources, of his own or of a friend or relative,
- [Who is entitled to the right to counsel?](https://6ac.org/abc-card/who-is-entitled-to-the-right-to-counsel/) - A person who is indigent.

## How Cards

- [How do state governments oversee right to counsel services?](https://6ac.org/how-card/how-do-state-governments-oversee-right-to-counsel-services/) - States oversee services either by directly delivering services or by setting and enforcing standards. A state can oversee right to counsel services by creating a state oversight entity. A state oversight entity can be either a (1) state oversight commission with a central office to manage the day-to-day operations of overseeing services, or (2) state
- [Are there attorney compensation models governments should avoid?](https://6ac.org/how-card/are-there-compensation-models-governments-should-avoid/) - Yes. Certain compensation models create conflicts of interests between the attorney’s financial interests and the defendant’s right to effective assistance of counsel and should be avoided: any type of flat fee, low hourly rates, an hourly rate with low caps, and any model that requires attorneys to pay for case-related expenses out of their compensation package.
- [How must government pay private attorneys for their appointed work?](https://6ac.org/how-card/how-must-government-pay-private-attorneys/) - To prevent conflicts of interest, private attorneys must be paid “reasonable compensation” for “all hours necessary to provide quality representation.” The hourly rate should account for overhead costs (e.g., office rent, utilities) and attorney pay. Attorneys should also be reimbursed for case-related expenses such as investigators, social workers, immigration consults, experts, postage, jail calls, and
- [Is there a preferred administration model?](https://6ac.org/how-card/is-there-a-preferred-administration-model/) - Yes. State administration and hybrid state-local administration through a mandatory state standards program. Local government officials often do not have the legal background required to administer a public defense system that meets all the state’s complex and evolving constitutional obligations. Centralizing administrative authority at the state level ensures that decisions are made by policymakers with
- [Are all hybrid state-local government administration models the same?](https://6ac.org/how-card/are-all-hybrid-state-locale-government-administration-models-the-same/) - No. "Hybrid state-local administration” means that both state and local government employees share the authority to decide how public defense services are delivered and which attorneys are eligible to deliver those services. This can occur in various ways, such as sharing administration responsibilities by geographic locale, case type, court level, or a mandatory state standards
- [What does “administering public defense services” mean?](https://6ac.org/how-card/how-is-administration-defined/) - “Administering public defense services” is defined as the government employee(s) authorized to make decisions regarding (1) how public defense services are delivered and (2) which attorneys are eligible to deliver those services.
- [How do state governments administer the right to counsel?](https://6ac.org/how-card/how-do-state-governments-administer-the-right-to-counsel/) - There are three models for administering right to counsel services: (1) state administration, (2) hybrid state-local administration, and (3) local administration.
- [Does every state oversee all right to counsel services in their state?](https://6ac.org/how-card/does-every-state-entity-oversee-all-right-to-counsel-services-in-their-state/) - No. A state oversight entity has “statewide oversight” if it oversees all aspects of indigent defense services for all case type at all levels of courts. “Partial state oversight” is a state oversight entity that oversees only some aspects of indigent defense services, such as only some case-types or some levels of court.
- [Are all hybrid state-local funding models the same?](https://6ac.org/how-card/are-all-hybrid-state-local-government-funding-models-the-same/) - No. Hybrid state-local funding means that both state and local governments are required to share responsibility for funding the entirety of services. This can occur in three main ways: (1) state-funded, with mandatory local contributions, (2) split responsibilities, and (3) standards-based, with mandatory state contributions.
- [Is there a preferred model for funding the right to counsel?](https://6ac.org/how-card/is-there-a-preferred-model-for-funding-the-right-to-counsel/) - Yes. National standards call for state funding rather than local or shared state-local funding. States are ultimately responsible for ensuring services are adequately funded. National standards prioritize state funding over other models because local jurisdictions most in need of services are often the least able to afford it. Factors that limit local revenue – such as
- [How do states fund the right to counsel?](https://6ac.org/how-card/how-do-state-governments-fund-the-right-to-counsel/) - There are four models for funding services: (1) state funding, (2) hybrid state-local funding, (3) local funding, or (4) alternative funding (e.g., local fines and fees).
- [What is a state commission, and how should it be made up?](https://6ac.org/how-card/what-is-a-state-commission-and-how-should-it-be-made-up/) - A state commission is a statutorily created entity with appointees that is vested with overseeing public defense services. A state commission should be independent and exercise oversight statewide. A state commission should consist of 9-13 members that “represent a diversity of factions in order to ensure insulation from partisan politics” so that no single branch
- [Do public defenders or private attorneys provide better services?](https://6ac.org/how-card/do-public-defenders-or-private-attorneys-provide-better-services/) - This question is not as important as one might think. First, the U.S. Constitution does not require a specific delivery model. Second, the delivery model is less important to the effectiveness of indigent defense services than ensuring that whatever model is chosen meets the hallmarks of an effective indigent defense system: the early appointment of
- [What is a public defender?](https://6ac.org/how-card/how-is-the-term-government-employed-staff-attorneys-defined/) - A public defender is a government-employed staff attorney who may be employed by any level of government (state, county, or municipality), full-time or part-time. Full-time public defenders are generally barred from carrying private cases, receive government benefits (e.g., health insurance, retirement), and are given government office space to work in. Part-time public defenders are generally
- [How do state governments deliver right to counsel services?](https://6ac.org/how-card/how-do-state-governments-deliver-right-to-counsel-services/) - There are only two models for delivering indigent defense services: (1) public defenders (government-employed staff attorneys) and (2) private attorneys.
- [Are right to counsel services always administered out of the same branch of government in each state?](https://6ac.org/how-card/are-right-to-counsel-services-always-administered-out-of-the-same-branch-of-government-in-each-state/) - No. There is currently no constitutional requirement as to which branch of government criminal public defender services must be housed. However, most states that have a state entity administer services out of the executive branch.
- [Is “alternative funding” effective?](https://6ac.org/how-card/is-alternative-funding-effective/) - Alternative revenue sources do not work as a primary source of indigent defense funding because there is no correlation between the resources needed to provide effective indigent defense services and the funding raised through alternative means.

## Timeline Events

- [New Mexico citizens vote to pass a constitutional amendment to create a Public Defender Commission, which oversees the Law Offices of the Public Defender. This is the first state to ensure independence of the defense function in its state constitution.](https://6ac.org/timeline-event/new-mexico-citizens-vote-to-pass-a-constitutional-amendment-to-create-a-public-defender-commission-which-oversees-the-law-offices-of-the-public-defender-this-is-the-first-state-to-ensure-independenc/) - In 1973, New Mexico passes the Public Defender Act, which creates a state-funded and state-administered indigent defense system. In 2012, New Mexico passes a constitutional amendment, which leads to the signing of the 2013 Public Defender Act, creating an independent commission under the judicial branch to oversee the New Mexico public defender department.
- [The Commonwealth of the Northern Mariana Islands Constitution establishes a right to counsel in all criminal cases.](https://6ac.org/timeline-event/the-commonwealth-of-the-northern-mariana-islands-constitution-establishes-a-right-to-counsel-in-all-criminal-cases/) - "In all criminal prosecutions, certain fundamental rights shall obtain. (a) the accused has the right to assistance of counsel and, if convicted, has the right to counsel in all appeals." N. Mar. I. Const. art. I, § 4 (ratified 1977).
- [The Sixth Amendment of the U.S. Constitution and the Fourteenth Amendment due process clause apply in the Commonwealth of the Northern Mariana Islands.](https://6ac.org/timeline-event/the-sixth-amendment-of-the-u-s-constitution-and-the-fourteenth-amendment-due-process-clause-apply-in-the-commonwealth-of-the-northern-mariana-islands/) - "To the extent that they are not applicable of their own force, the following provisions of the Constitution of the United States will be applicable within the Northern Mariana Islands as if the Northern Mariana Islands were one of the several states: … Amendments 1 through 9, inclusive; … Amendment 14, Section 1…." Pub. L.
- [The Hawai'i Office of the Public Defender is established.](https://6ac.org/timeline-event/the-hawaii-office-of-the-public-defender-is-established/) - The Hawai'i Office of the Public Defender provides primary indigent defense services in the state.
- [New Hampshire law requires the appointment of counsel in all criminal cases, except petty offenses.](https://6ac.org/timeline-event/new-hampshire-law-requires-the-appointment-of-counsel-in-all-criminal-cases-except-petty-offenses/) - "In every criminal case in which the defendant is charged with a felony or a misdemeanor other than a petty offense, and appears without counsel, the court before which he appears shall advise the defendant that he has a right to be represented by counsel and that counsel will be appointed to represent him if
- [Alaska court rule requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/alaska-court-rule-requires-the-appointment-of-counsel-in-all-criminal-cases/) - "If the defendant states that he desires the aid of counsel and is unable to employ counsel, and upon his making affidavit that he is without sufficient funds to employ counsel, the court shall assign counsel to represent him at every stage of the proceedings, who shall be allowed such fee for his services as
- [The North Carolina Supreme Court holds that that counsel must be appointed in capital cases.](https://6ac.org/timeline-event/the-north-carolina-supreme-court-holds-that-that-counsel-must-be-appointed-in-capital-cases/) - "The right to have counsel as well as the right of confrontation is guaranteed [in the state constitution]… Where the crime charged is a capital felony this right becomes a mandate." State v. Farrell, 223 N.C. 321 (1943).
- [The U.S. Virgin Islands Organic Act establishes the right to counsel in all criminal cases.](https://6ac.org/timeline-event/the-us-virgin-islands-organic-act-establishes-the-right-to-counsel-in-all-criminal-cases/) - "No law shall be enacted in the Virgin Islands which shall deprive any person of life, liberty, or property without due process of law or deny to any person therein equal protection of the laws. In all criminal prosecutions the accused shall enjoy the right to be represented by counsel for his defense…" Organic Act
- [The Defender Association of Philadelphia is founded as a non-profit organization providing limited representation in some criminal cases.](https://6ac.org/timeline-event/the-defender-association-of-philadelphia-is-founded-as-a-non-profit-charitable-organization-providing-limited-representation-in-some-criminal-cases/) - Post-Gideon, the Defender Association becomes the primary indigent defense provider in the county.
- [Hawai'i Territory law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/hawaii-territory-law-requires-the-appointment-of-counsel-in-felony-cases/) - "In any felony case pending in a circuit court, where the person accused requests counsel for his defense and shows to the satisfaction of the court that he is unable to obtain such counsel, the court shall assign him counsel from among the attorneys licensed to practise in courts of record and may allow such
- [Connecticut law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/connecticut-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - "The judges of the superior court… or any judge thereof designated to hold any criminal term of said court…. Shall appoint an attorney-at-law, of at least five years' practice, to act as attorney in the defense of all persons charged with crime in said court when such person is without funds sufficient to employ counsel
- [Montana Territory law requires compensation for court-appointed counsel.](https://6ac.org/timeline-event/the-montana-territorial-legislature-adopts-the-first-statute-relating-to-the-compensation-of-court-appointed-counsel/) - Counsel was entitled to reasonable payment for his services by the county, "not to exceed in any capital case the sum of fifty dollars; in other cases of felony a sum not exceeding twenty-five dollars; and in other cases a sum not exceeding ten dollars." James Park Taylor, Bespeaking Justice: A History of Indigent Defense
- [Illinois law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/illinois-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - "Every person charged with crime shall be allowed counsel, and when he shall state upon oath that he is unable to procure counsel, the court shall assign him competent counsel, who shall conduct his defense." Ill. Rev. Stat., div. 13, § 2 (1874).
- [The Georgia Supreme Court states in dicta that the law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/the-georgia-supreme-court-states-in-dicta-that-the-law-requires-the-appointment-of-counse-in-all-criminal-cases/) - Dicta is a comment or observation by the judge in a legal opinion; it is not legally binding but can be cited as persuasive authority. "The constitutional guaranty that 'every person charged with an offense against the law shall have the privilege and benefit of counsel,' should be strictly guarded and preserved. So deeply grafted
- [California law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/california-law-requires-the-appointnent-of-counsel-in-all-criminal-cases/) - "If the defendant appears for arraignment without counsel, he must be informed by the court that it is his right to have counsel before being arraigned, and must be asked if he desires the aid of counsel. If he desires and is unable to employ counsel, the court must assign counsel to defend him." Cal.
- [Nevada Territory law allows the appointment of counsel in criminal cases, but does not mandate it.](https://6ac.org/timeline-event/nevada-territory-law-allows-the-appointment-of-counsel-in-criminal-cases-but-does-not-mandate-it/) - "If the defendant appear for arraignment without counsel, he shall be informed by the Court that it is his right to have counsel before being arraigned, and shall be asked if he desire the aid of counsel." The Laws of the Territory of Nevada, An Act to Regul. Proc. in Crim. Cases in the Cts.
- [Michigan law requires an attorney to be paid a fee when appointed to criminal cases.](https://6ac.org/timeline-event/michigan-law-requires-an-attorney-to-be-paid-a-fee-when-appointed-to-criminal-cases/) - "That an Attorney appointed by a Court to defend a person indicted for any offence, on account of such person being unable to procure counsel, shall be entitled to receive from the County Treasury, on the certificate of the presiding Judge that such services have been duly rendered, on of the following fees: For defending
- [Iowa Territory law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/iowa-territory-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - "[T]he Court shall assign counsel to defend the prisoner, in case he cannot procure counsel himself." The Statute Laws of the Territory of Iowa, ch. 5, § 64 (1839).
- [Louisiana law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/louisiana-law-requires-the-appointment-of-counsel-in-felony-cases/) - "At the time when the accused is called to make his exception to the indictment, he shall be asked by the court whether he has counsel; and if he shall allege that he is unable to procure counsel, the court shall assign some licensed attorney to conduct his defence under his direction." A Code of
- [Arkansas Territory law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/arkansas-territory-law-requires-the-appointment-of-counsel-in-capital-cases/) - "Any person who shall be accused and indicted of any capital offence shall… be allowed and admitted to make his full defence by counsel learned in the law; and the court before whom such person shall be tried, or some judge thereof, shall and they are hereby authorised and required immediately upon his request, to
- [Mississippi Territory law requires the appointment of counsel in capital cases. Until 1817, Alabama is part of the Mississippi Territory.](https://6ac.org/timeline-event/mississippi-territory-law-requires-the-appointment-of-counsel-in-capital-cases-until-1817-alabama-is-part-of-the-mississippi-territory/) - "That any person who shall be indicted for any capital crime… shall be allowed and admitted to make his full defence by counsel learned in the law. And the court before whom such person shall be tried, or some judge thereof, shall immediately upon his or her request, assign to such person such counsel, not
- [Arkansas law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/arkansas-law-requires-the-appointment-of-counsel-in-felony-cases/) - "If any person about to be arraigned upon an indictment for a felony, be without counsel to conduct his defence, and shall be unable to employ any, it shall be the duty of the court to assign him counsel, at his request, not exceeding two, who shall have free access to the prisoner at all
- [Massachusetts law allows the appointment of counsel in capital cases, but does not mandate it.](https://6ac.org/timeline-event/massachusetts-law-allows-the-appointment-of-counsel-in-capital-cases-but-does-not-mandate-it/) - "Be it further enacted, That whenever any indictment for a capital offence, shall be found at any term of said Court, holden by one Justice thereof, it shall be lawful for the Court to cause the person indicted to be arraigned… and if such person shall deny the charge, and put himself or herself upon
- [The first American Samoan Constitution establishes the right to counsel in all criminal cases.](https://6ac.org/timeline-event/the-first-american-samoan-constitution-establishes-the-right-to-counsel-in-all-criminal-cases/) - "Every person charged with an offence has the following minimum rights: … To defend himself in person or through legal assistance of his own choosing and, if he has not sufficient means to pay for legal assistance, to be given it free when the interest of justice so require…." Am. Samoa Const. of 1960, pt.
- [The islands of Tutuila and Manua become U.S. territories; other islands would later be added and become known as American Samoa.](https://6ac.org/timeline-event/the-islands-of-tutuila-and-manua-become-us-territories-other-islands-would-later-be-added-and-become-known-as-american-samoa/)
- [The Office of the Territorial Public Defender is established by the U.S. Virgin Islands Legislature. In 2022, the U.S. Virgin Islands Supreme Court establishes the Office of Conflict Counsel.](https://6ac.org/timeline-event/the-office-of-the-territorial-public-defender-is-established-by-the-us-virgin-islands-legislature-in-2022-the-us-virgin-islands-supreme-court-establishes-the-office-of-conflict-counsel/)
- [Louisiana statehood & State Constitution](https://6ac.org/timeline-event/louisiana-statehood-state-constitution/) - Article VI, § 18: "In all criminal prosecutions, the accused have the right of being heard by himself or counsel." This was amended in 1975 to include an affirmative right to counsel: “In a criminal prosecution, an accused shall be informed of the nature and cause of the accusation against him. At each stage of
- [New Jersey law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/new-jersey-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - "And be it enacted by the authority aforesaid, That the court before whom any person shall be tried upon indictment, is hereby authorized and required to assign to such person, if not of ability to procure counsel, such counsel, not exceeding two, as he or she shall desire, to whom such counsel shall have free
- [Massachusetts statehood; State Constitution in effect since 1780](https://6ac.org/timeline-event/massachusetts-statehood-state-constitution-in-effect-since-1780/) - Article XII: "No subject shall be held to answer for any crimes or no offence until … fully heard in his defence by himself, or his counsel at his election." Until 1820, Maine is part of Massachusetts.
- [Georgia statehood; State Constitution in effect since 1777](https://6ac.org/timeline-event/georgia-statehood-state-constitution-in-effect-since-1777/) - The Georgia Constitution first mentions a right to counsel in 1798: "[N]o person shall be debarred from advocating or defending his cause before any court or tribunal, either by himself or counsel, or both." Ga. Const. art. III, § 8 (1798). Then, in 1983, it was amended to state, "Every person charged with an offense
- [North Carolina law allows for the right to counsel in criminal cases, but does not mandate it.](https://6ac.org/timeline-event/north-carolina-law-allows-for-the-right-to-counsel-in-criminal-cases-but-does-not-mandate-it/) - "[E]very person accused of any crime or misdemeanor whatsoever, shall be entitled to council, in all matters which may be necessary for his defense as well as to facts as to law." Laws of North Carolina, § 94 (1777).
- [Boston Massacre Trial](https://6ac.org/timeline-event/boston-massacre-trial/) - John Adams risked his reputation for ideals of liberty by defending the British soldiers involved in the Boston Massacre in court. “The Part I took in Defence of Cptn. Preston and the Soldiers, procured me Anxiety, and Obloquy enough. It was, however, one of the most gallant, generous, manly and disinterested Actions of my whole
- [Magna Carta enacted](https://6ac.org/timeline-event/magna-carta-enacted/) - The Magna Carta prohibits counsel in cases against the King (felonies), while permitting counsel in cases against citizens (misdemeanors). "Originally, in England, a person charged with treason or felony was denied the aid of counsel, except in respect of legal questions which the accused himself might suggest. At the same time, parties in civil cases
- [Oregon statehood & State Constitution](https://6ac.org/timeline-event/oregon-statehood-state-constitution/) - Article I, § 11: "That in all criminal prosecutions, the accused hath a right to be heard by himself or counsel."
- [Hawai'i statehood & State Constitution](https://6ac.org/timeline-event/hawaii-statehood-state-constitution/) - Article I, § 14: “In all criminal prosecutions, the accused shall enjoy the right … to have the assistance of counsel for the accused's defense.”
- [Alaska statehood & State Constitution](https://6ac.org/timeline-event/alaska-statehood-state-constitution/) - Article 1, § 11: "In all criminal prosecutions, the accused shall have the right to … have the assistance of counsel for his defense."
- [Puerto Rico law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/puerto-rico-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - "If the accused appears to answer the accusation without a lawyer, the court must inform him of his right to have a defense lawyer before the indictment is read and ask him if he wishes to have a lawyer. If he answers affirmatively and is not in a position to employ one, the court must
- [The Kentucky Supreme Court states in dicta that indigent defendants in all criminal cases should be appointed counsel.](https://6ac.org/timeline-event/the-kentucky-supreme-court-states-in-dicta-that-indigent-defendants-in-all-criminal-cases-should-be-appointed-counsel/) - Dicta is a comment or observation by the judge in a legal opinion; it is not legally binding but can be cited as persuasive authority. “The Constitution of the state, in section 11, declares in part that, 'in all criminal prosecutions the accused has the right to be heard by himself and counsel,' and nobody
- [New Mexico statehood & State Constitution](https://6ac.org/timeline-event/new-mexico-statehood-state-constitution/) - Article II, § 14: "In all criminal prosecutions, the accused shall have the right to appear and defend himself in person, and by counsel."
- [Arizona statehood & State Constitution](https://6ac.org/timeline-event/arizona-statehood-state-constitution/) - Article II, § 24: "In criminal prosecutions, the accused shall have the right to appear and defend in person, and by counsel."
- [Oklahoma statehood & State Constitution](https://6ac.org/timeline-event/oklahoma-statehood-state-constitution/) - Article II, § 20: "In criminal prosecutions the accused shall have the right to be heard by himself and counsel."
- [Utah statehood & State Constitution](https://6ac.org/timeline-event/utah-statehood-state-constitution/) - Article I, § 12: "In criminal prosecutions the accused shall have the right to appear and defend in person and by counsel."
- [Wyoming statehood & State Constitution](https://6ac.org/timeline-event/wyoming-statehood-state-constitution/) - Article I, § 10: "In all criminal prosecutions he accused shall have the right to defend in person and by counsel."
- [Idaho statehood & State Constitution](https://6ac.org/timeline-event/idaho-statehood-state-constitution/) - Article I, § 13: "In all criminal prosecutions, the party accused shall have the right to a speedy and public trial; to have the process of the court to compel the attendance of witnesses in his behalf, and to appear and defend in person and with counsel."
- [Montana statehood & State Constitution](https://6ac.org/timeline-event/montana-statehood-state-constitution/) - Article II, § 24: "In all criminal prosecutions the accused shall have the right to appear and defend in person and by counsel."
- [Washington statehood & State Constitution](https://6ac.org/timeline-event/washington-statehood-state-constitution/) - Article I, § 22: "In criminal prosecutions the accused shall have the right to appear and defend in person, or by counsel."
- [South Dakota statehood & State Constitution](https://6ac.org/timeline-event/south-dakota-statehood-state-constitution/) - Article VI, § 7: "In all criminal prosecutions the accused shall have the right to defend in person and by counsel."
- [North Dakota statehood & State Constitution](https://6ac.org/timeline-event/north-dakota-statehood-state-constitution/) - Article I, § 13: "In criminal prosecutions in any court whatever, the party accused shall have the right ... to appear and defend in person and with counsel."
- [Colorado statehood & State Constitution](https://6ac.org/timeline-event/colorado-statehood-state-constitution/) - Article 11, § 16: "In criminal prosecutions the accused shall have the right to appear and defend in person and by counsel."
- [Nebraska statehood & State Constitution](https://6ac.org/timeline-event/nebraska-statehood-state-constitution/) - Article I, § 11: "In all criminal prosecutions the accused shall have the right to appear and defend in person or by counsel."
- [Nevada statehood & State Constitution](https://6ac.org/timeline-event/nevada-statehood-state-constitution/) - Article I, § 8: “...in any trial, in any court whatever, the party accused shall be allowed to appear and defend in person, and with counsel."
- [West Virginia statehood & State Constitution](https://6ac.org/timeline-event/west-virginia-statehood-state-constitution/) - Article II, § 8: "The trial of crimes and misdemeanors... the accused ...shall have the assistance of counsel for his defence, and compulsory process for obtaining witnesses in his favor."
- [Kansas statehood & State Constitution](https://6ac.org/timeline-event/kansas-statehood-state-constitution/) - Article 1, § 10: "In all prosecutions, the accused shall be allowed to appear and defend in person, or by counsel."
- [Minnesota statehood & State Constitution](https://6ac.org/timeline-event/minnesota-statehood-state-constitution/) - Article I, § 6: "In all criminal prosecutions the accused shall enjoy the right ... to have the assistance of counsel in his defense."
- [The Illinois Supreme Court holds that counsel must be appointed in all criminal cases.](https://6ac.org/timeline-event/the-illinois-supreme-court-holds-that-counsel-must-be-appointed-in-all-criminal-cases/) - "In criminal prosecutions, ... the court, in case of inability of the accused to obtain counsel, will appoint counsel for him, and may compel the counsel, as an officer of the court, subject to its authority, to defend the accused against unjust conviction." Vise v. Hamilton Cnty., 19 Ill. 78 (1857).
- [California statehood & State Constitution](https://6ac.org/timeline-event/california-statehood-state-constitution/) - Article I, § 8: "No person shall be held to answer for a capital or otherwise infamous crime ... unless ...the party accused shall be allowed to appear and defend in person and with counsel."
- [Wisconsin statehood & State Constitution](https://6ac.org/timeline-event/wisconsin-statehood-state-constitution/) - Article I, § 7: "That in all criminal prosecutions, the accused hath a right to be heard by himself or counsel."
- [Iowa statehood & State Constitution](https://6ac.org/timeline-event/iowa-statehood-state-constitution/) - Article I, § 10: "In all criminal prosecutions, and in cases involving the life, or liberty of an individual the accused shall have ... the assistance of counsel."
- [Texas statehood; State Constitution in effect since 1836 and new Texas Constitution adopted in 1876](https://6ac.org/timeline-event/texas-statehood-state-constitution-in-effect-since-1836-and-new-texas-constitution-adopted-in-1876/) - Article I, § 10: “In all criminal prosecutions the accused shall have … the right of being heard by himself or counsel, or both."
- [Florida statehood & State Constitution](https://6ac.org/timeline-event/florida-statehood-state-constitution/) - Article I, § 10: "That in all criminal prosecutions, the accused hath a right to be heard by himself or counsel."
- [Michigan statehood; State Constitution in effect since 1835](https://6ac.org/timeline-event/michigan-statehood-state-constitution-in-effect-since-1835/) - Article I, § 10: "In all criminal prosecutions, the accused shall have the right to ... have the assistance of counsel for his defense."
- [Arkansas statehood & State Constitution](https://6ac.org/timeline-event/arkansas-statehood-state-constitution/) - Article II, § 10: "In all criminal prosecutions, the accused shall enjoy the right to … be heard by himself and his counsel."
- [The Republic of Texas created & Constitution](https://6ac.org/timeline-event/the-republic-of-texas-created-constitution/) - The Constitution for the Republic of Texas (1836) contains a Declaration of Rights: "In all criminal prosecutions the accused shall have the right of being heard, by himself, or council."
- [Missouri statehood & State Constitution](https://6ac.org/timeline-event/missouri-statehood-state-constitution/) - Article XIII, § 9: "That, in all criminal prosecutions, the accused has the right to be heard by himself and his counsel."
- [Maine statehood & State Constitution](https://6ac.org/timeline-event/maine-statehood-state-constitution/) - Article I, § 6: "In all criminal prosecutions, the accused shall have a right to be heard by himself and his counsel."
- [Alabama statehood & State Constitution](https://6ac.org/timeline-event/alabama-statehood-state-constitution/) - Article I, § 10: "In all criminal prosecutions, the accused has a right to be heard by himself, and counsel."
- [Illinois statehood & State Constitution](https://6ac.org/timeline-event/illinois-statehood-state-constitution/) - Article VIII, § 9: "That in all criminal prosecutions, the accused hath a right to be heard by himself and counsel."
- [Mississippi statehood & State Constitution](https://6ac.org/timeline-event/mississippi-statehood-state-constitution/) - Article I, § 10: "That in all criminal prosecutions, the accused hath a right to be heard by himself and counsel."
- [Indiana statehood & State Constitution](https://6ac.org/timeline-event/indiana-statehood-state-constitution/) - Article I, § 13: "That in all criminal prosecutions, the accused hath a right to be heard by himself and counsel."
- [Tennessee statehood & State Constitution](https://6ac.org/timeline-event/tennessee-statehood-state-constitution/) - Article XI, § 10: "That in all criminal prosecutions the accused hath a right to be heard by himself and his Counsel."
- [Connecticut statehood; State Constitution ratified in 1818](https://6ac.org/timeline-event/connecticut-statehood-state-constitution-ratified-in-1818/) - Article I, § 9: "In all criminal prosecutions the accused shall have a right to be heard by himself and by counsel."
- [Ohio statehood & State Constitution](https://6ac.org/timeline-event/ohio-statehood-state-constitution/) - Article VIII, § 11: "That in all criminal prosecutions the accused has a right to be heard by himself and his counsel."
- [Kentucky statehood & State Constitution](https://6ac.org/timeline-event/kentucky-statehood-state-constitution/) - Article XI, § 10: "That, in all prosecutions for criminal offences, a man hath a right to be heard, by himself and his counsel."
- [Rhode Island statehood; State Constitution ratified in 1842](https://6ac.org/timeline-event/rhode-island-statehood-state-constitution-ratified-in-1842/) - Article I, § 10: “In all criminal prosecutions, accused persons shall enjoy the right … to have the assistance of counsel in their defense.”
- [North Carolina statehood; State Constitution in effect since 1778](https://6ac.org/timeline-event/north-carolina-statehood-state-constitution-in-effect-since-1778/) - Article I, § 23: "In all criminal prosecutions, every person charged with crime has the right … to have counsel for defense."
- [New York statehood; State Constitution in effect since 1777](https://6ac.org/timeline-event/new-york-statehood-state-constitution-in-effect-since-1777/) - Article XXXIV: "That in every trial on impeachment, or indictment for crimes or misdemeanors, the party impeached or indicted shall be allowed counsel, as in civil actions."
- [New Hampshire statehood; State Constitution in effect since 1784](https://6ac.org/timeline-event/new-hampshire-statehood-state-constitution-in-effect-since-1784/) - Article XV: “Every subject shall have a right to … be fully heard in his defense, by himself, and counsel.” Amended in 1966 to include: “Every person held to answer in any crime or offense punishable by deprivation of liberty shall have the right to counsel at the expense of the state if need is
- [South Carolina statehood; State Constitution in effect since 1778](https://6ac.org/timeline-event/south-carolina-statehood-state-constitution-in-effect-since-1778/) - Article XXIII: "[N]o judgment of the said court, except judgment of acquittal, shall be valid, unless it shall be assented to by two-third parts of the members then present, and on every trial, as well on impeachments as others, the party accused shall be allowed counsel."
- [Pennsylvania statehood; State Constitution in effect since 1776](https://6ac.org/timeline-event/pennsylvania-statehood-state-constitution-in-effect-since-1776/) - Article IX: "That in all prosecutions for criminal offences, a man hath a right to be heard by himself and his council."
- [Delaware statehood; State Constitution in effect since 1776](https://6ac.org/timeline-event/delaware-statehood-state-constitution-in-effect-since-1776/) - Article I, § 7: "In all criminal prosecutions, the accused hath a right to be heard by himself and his counsel."
- [New Hampshire law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/new-hampshire-law-requires-the-appointment-of-counsel-in-capital-cases/) - "And be it further enacted, That every person indicted for treason, or any other crime, the punishment of which is death, shall… at his request, have counsel learned in the law assigned him by the court, not exceeding two, and such counsel shall have access to the prisoner at all seasonable hours...." An Act for
- [South Carolina law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/south-carolina-law-requires-the-appointment-of-counsel-in-capital-cases/) - "And in case any person…shall desire council, the court…is hereby authorized and required, immediately, upon his or their request, to assign…such and so many council not exceeding two, as the person or persons shall desire, to whom such council shall have free access at all reasonable times." Laws of the Province of South Carolina, Acts
- [Pennsylvania law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/pennsylvania-law-requires-the-appointment-of-counsel-in-capital-cases/) - "[U]pon all trials of the said capital crimes, lawful challenges shall be allowed, and learned counsel assigned to the prisoners." The Statutes at Large of Pennsylvania, Act of May 31, 1718, ch. 236, § 3 (Busch, 1896).
- [Idaho Territory law allows the appointment of counsel in criminal cases, but does not mandate it.](https://6ac.org/timeline-event/idaho-territory-law-allows-the-appointment-of-counsel-in-criminal-cases-but-does-not-mandate-it/) - "Whenever upon the trial of a person upon an indictment it shall appear to the satisfaction of the Court that the accused is poor, and unable to procure the services of counsel, the Court may appoint counsel to conduct the defense of the accused, for which service such counsel shall be paid out of the
- [Utah Territory law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/utah-territory-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [The Rhode Island Act of March 11, 1660, is the first statute allowing for the right to counsel in criminal cases.](https://6ac.org/timeline-event/the-rhode-island-act-of-march-11-1660-is-the-first-statute-allowing-for-the-right-to-counsel-in-criminal-cases/) - "[W]hereas it doth appeare that any person... may on good grounds, or through mallice and envie be indicted and accused for matters criminall, wherein the person that is soe [accused] may be innocent, and yett may not bee accomplished with soe much wisdome and knowlidge of the law as to plead his owne innoceneye.. Be
- [Oklahoma Territory law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/oklahoma-territory-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Wyoming law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/wyoming-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Start of Revolutionary War](https://6ac.org/timeline-event/start-of-revolutionary-war/)
- [The New York Office of Indigent Legal Services is created.](https://6ac.org/timeline-event/the-new-york-office-of-indigent-legal-services-is-created/) - In New York, the funding and administration of indigent defense services in adult criminal trials is the responsibility of local governments. The state reimburses a portion of the costs through a standards-based program. In 2010, the Office of Indigent Legal Services is created to set standards for and provide limited oversight of local indigent defense
- [The Alabama Office of Indigent Defense Services is created.](https://6ac.org/timeline-event/the-alabama-office-of-indigent-defense-services-is-created/) - Within a year, Jefferson County (Birmingham) creates a public defender office. Montgomery County follows suit in 2013. Major urban areas in the state move away from providing services through appointed private attorneys towards public defender offices.
- [Illinois law requires the state to pay two-thirds of each county public defender's salary.](https://6ac.org/timeline-event/illinois-law-requires-the-state-to-pay-two-thirds-of-each-county-public-defenders-salary/)
- [The Michigan Indigent Defense Commission is created.](https://6ac.org/timeline-event/the-michigan-indigent-defense-commission-is-created/) - Since 2013, Michigan's state funding through the Michigan Indigent Defense Commission has been tied to local indigent defense systems' meeting of mandatory state standards.
- [The Idaho Public Defense Commission is established.](https://6ac.org/timeline-event/the-idaho-public-defense-commission-is-established/) - The establishment of the Idaho Public Defense Commision demarks the first major step towards state-administration and state-funding of indigent defense services in Idaho. Over time, greater funding and state-involvement occurs until 2024 when the Idaho State Public Defender is established to provide 100% state funding through regional public defender offices.
- [The Delaware  Office of Defense Services is established.](https://6ac.org/timeline-event/the-delaware-office-of-defense-services-is-established/)
- [The Utah Indigent Defense Commission is created.](https://6ac.org/timeline-event/the-utah-indigent-defense-commission-is-created/) - Utah delegates the responsibility for funding and administering trial-level indigent defense services to its local governments, with state funding available to localities through an optional, competitive, standards-based grant program. A state commission is responsible for providing limited oversight of local indigent defense services.
- [California expands the Office of the State Public Defender to provide financial aid and training support to counties.](https://6ac.org/timeline-event/california-expands-the-office-of-the-state-public-defender-to-provide-financial-aid-and-training-support-to-counties/) - In 1967, the Office of the State Public Defender is established to provide representation in death penalty post-conviction cases. In 2020, OSPD expands to provide county support at the trial level, including training and technical assistance.
- [The Pennsylvania Indigent Defense Advisory Committee is established.](https://6ac.org/timeline-event/the-pennsylvania-indigent-defense-advisory-committee-is-established/) - In 2023, Pennsylvania creates the Indigent Defense Advisory Committee, which provides some oversight over local indigent defense services, sets standards for indigent defense, and provides training to attorneys.
- [The South Dakota Commission on Indigent Legal Services is created.](https://6ac.org/timeline-event/the-south-dakota-commission-on-indigent-legal-services-is-created/) - In 2024, South Dakota creates the South Dakota Commission on Indigent Legal Services to provide limited oversight of local indigent defense and oversee a State Appellate Defender Office.
- [Texas law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/texas-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [West Virginia court rule requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/west-virginia-court-rule-requires-the-appointment-of-counsel-in-felony-cases/)
- [Washington law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/washington-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Utah law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/utah-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [South Carolina law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/south-carolina-law-requires-the-appointment-of-counsel-in-capital-cases-2/)
- [The Wisconsin State Public Defender is established.](https://6ac.org/timeline-event/the-wisconsin-state-public-defender-is-established/) - The Wisconsin State Public Defender is a statewide, state-funded agency, which provides representation through public defender offices and a managed assigned counsel program.
- [The Iowa State Public Defender Office is created.](https://6ac.org/timeline-event/the-iowa-state-public-defender-office-is-created/) - Iowa assumes the cost of all trial-level indigent defense services.
- [The Indiana Public Defender Commission, known today as the Indiana Commission on Court Appointed Attorneys, is created.](https://6ac.org/timeline-event/the-indiana-public-defender-commission-known-today-as-the-indiana-commission-on-court-appointed-attorneys-is-created/) - The Indiana Commission on Court Appointed Attorneys provides funding and oversight for public defense of local indigent defense systems. As of 2024, counties that opt-in and follow Commission standards could receive state reimbursement of up to 50% for capital case expenditures and up to 40% for felony cases expenditures.
- [Tennessee establishes the District Public Defender Conference and district public defender offices across the state.](https://6ac.org/timeline-event/tennessee-establishes-the-district-public-defender-conference-and-district-public-defender-offices-across-the-state/) - Tennessee funds the majority of its indigent defense services. In most judicial circuits, the state authorizes elected public defenders with the responsibility for administering primary services.
- [The Oklahoma Indigent Defense System is created.](https://6ac.org/timeline-event/the-oklahoma-indigent-defense-system-is-created/) - The Oklahoma Indigent Defense System funds, administers, and oversees all trial-level indigent defense services except for Tulsa and Oklahoma Counties.
- [The Arkansas Public Defender Commission is established.](https://6ac.org/timeline-event/the-arkansas-public-defender-commission-is-established/) - At its founding, the Arkansas Public Defender Commission provides oversight of county public defender offices. In 1997, it begins taking over the funding of the indigent defense system for state cases.
- [The South Carolina Commission on Indigent Defense is established.](https://6ac.org/timeline-event/the-south-carolina-commission-on-indigent-defense-is-established/) - South Carolina funds and oversees statewide indigent defense services through the South Carolina Commission on Indigent Defense. In 2007, the South Carolina Indigent Defense Act of 2007 replaces a system of non-profit defender corporations for a circuit public defender system.
- [The Nebraska Commission on Public Advocacy is established.](https://6ac.org/timeline-event/the-nebraska-commission-on-public-advocacy-is-established/) - The Nebraska Commission on Public Advocacy is established as a statewide commission to provide limited indigent defense services at state expense.
- [The Washington State Office of Public Defense is established.](https://6ac.org/timeline-event/the-washington-state-office-of-public-defense-is-established/) - Washington establishes the State Office of Public Defense to provide limited funding and oversight to local trial-level indigent defense systems.
- [The North Carolina Office of Indigent Defense Services is established.](https://6ac.org/timeline-event/the-north-carolina-office-of-indigent-defense-services-is-established/) - North Carolina funds and administers all indigent defense services. After the state's oversight commission was created, the state began adding public defender offices in addition to the two already in existence. As of July 1, 2024, there are 27 public defender offices covering 60 of 100 counties.
- [The Mississippi Office of Capital Defense Counsel is established in 2001 and combines with the Office of Indigent Appeals and the Defender Training Division to form the Office of the State Public Defender in 2011.](https://6ac.org/timeline-event/the-mississippi-office-of-capital-defense-counsel-is-established-in-2001-and-combines-with-the-office-of-indigent-appeals-and-the-defender-training-division-to-form-the-office-of-the-state-public-defe/) - Since 2001, Mississippi provides funding and administion of trial-level representation in capital cases. It also provides training and resources to public defenders and appointed counsel through the Office of the State Public Defender.
- [The Oregon Office of Public Defense Services Commission, now known as the Oregon Public Defense Commission, is created.](https://6ac.org/timeline-event/the-oregon-office-of-public-defense-services-commission-now-known-as-the-oregon-public-defense-commission-is-created/) - Since 1983, Oregon funds the majority of the costs of trial-level indigent defense systems. In 2023, Oregon begins the shift towards primarily utilizing full-time public defender for trial-level representation.
- [The Texas Task Force on Indigent Defense is created, which becomes the Texas Indigent Defense Commission in 2011.](https://6ac.org/timeline-event/the-texas-task-force-on-indigent-defense-is-created-which-becomes-the-texas-indigent-defense-commission-in-2011/) - Since 2001, Texas has greatly expanded in providing funding to local indigent defense systems and strengthening its network of public defender offices.
- [American Bar Association adopts the Ten Principles of a Public Defense Delivery System](https://6ac.org/timeline-event/american-bar-association-adopts-the-ten-principles-of-a-public-defense-delivery-system/) - The ABA Ten Principles "constitute the fundamental criteria necessary to design a system that provides effective, efficient, high quality, ethical, conflict-free legal representation for criminal defendants who are unable to afford an attorney." The ABA Principles were revised in 2023. The ABA recommends that “each jurisdiction swiftly assess its compliance with the [Principles] and implement
- [U.S. Supreme Court - Alabama v. Shelton](https://6ac.org/timeline-event/u-s-supreme-court-alabama-v-shelton/) - Alabama v. Shelton clarifies that the state is required to provide counsel in misdemeanor cases with a suspended sentence under the Sixth and Fourteenth Amendment. “[D]oes the Sixth Amendment permit activation of a suspended sentence upon the defendant's violation of the terms of probation? We conclude that it does not. A suspended sentence is a
- [The Virginia Indigent Defense Commission is created.](https://6ac.org/timeline-event/the-virginia-indigent-defense-commission-is-created/) - Virginia oversees, funds, and administers indigent defense services, including the management of court-appointed counsel, through the Virginia Indigent Defense Commission.
- [The Montana Public Defender Act creates the Office of the State Public Defender.](https://6ac.org/timeline-event/the-montana-public-defender-act-creates-the-office-of-the-state-public-defender/) - Montana funds, administers, and oversees all trial-level indigent defense services.
- [The North Dakota Commission on Legal Counsel for Indigents is created.](https://6ac.org/timeline-event/the-north-dakota-commission-on-legal-counsel-for-indigents-is-created/) - The North Dakota Commission on Legal Counsel for Indigents is a state funded commission that administers and oversees trial-level indigent defense services. It provides indigent defense services through state-employed public defenders and private attorneys.
- [The Public Defender Act of 2007 creates  the Louisiana Public Defender Board.](https://6ac.org/timeline-event/the-public-defender-act-of-2007-creates-the-louisiana-public-defender-board/) - Since 2007, Louisiana assumes an increasingly larger portion of the cost of indigent defense services. In 2024, the administration and oversight of indigent defense transfers from the Louisiana Public Defender Board to the Office of the State Public Defender.
- [The Maine Commission on Indigent Legal Services, known today as the Maine Commission of Public Defense Services, is created.](https://6ac.org/timeline-event/the-maine-commission-on-indigent-legal-services-known-today-as-the-maine-commission-of-public-defense-services-is-created/) - The Maine Commission on Public Defense Services administers indigent defense services primarily through private attorneys paid hourly. In 2023, the state's first public defender office, the Capital Region Public Defender, opens. Since then, additional public defender offices have opened across the state.
- [The Nevada State Public Defender is established.](https://6ac.org/timeline-event/the-nevada-state-public-defender-is-established/) - The Nevada State Public Defender is initially an executive branch agency overseen by an independent commission. The agency is charged with providing right to counsel services to indigent defendants in all counties other than Clark (Las Vegas) and Washoe (Reno). The commission is removed in 1975. With the creation of the Nevada Department of Indigent
- [U.S. Supreme Court - Argersinger v. Hamilton](https://6ac.org/timeline-event/u-s-supreme-court-argersinger-v-hamilton/) - Argersinger v. Hamlin clarifies that the state is required to provide appointed counsel in misdemeanor cases under the Sixth and Fourteenth Amendments. "We are by no means convinced that legal and constitutional questions involved in a case that actually leads to imprisonment even for a brief period are any less complex than when a person
- [The Kentucky Office of Public Defender, now the Department of Public Advocacy, is established.](https://6ac.org/timeline-event/the-kentucky-office-of-public-defender-now-the-department-of-public-advocacy-is-established/) - In 1972, Kentucky creates the statewide public defender office to provide trial-level representation. In 2024, Kentucky's indigent defense system becomes fully state-funded and administered with the merger of the Louisville-Jefferson County Public Defender's Office into the state system.
- [The Missouri State Public Defender System is created, and four years later in 1976, the Missouri Public Defender Commission is created to oversee the office.](https://6ac.org/timeline-event/the-missouri-state-public-defender-system-is-created-and-four-years-later-in-1976-the-missouri-public-defender-commission-is-created-to-oversee-the-office/) - Missouri provides funding and oversight for the majority of trial-level indigent defense services.
- [The New Hampshire Public Defender is established as a pilot project of New Hampshire Legal Assistance. It becomes a stand-alone non-profit organization in 1985.](https://6ac.org/timeline-event/the-new-hampshire-public-defender-is-established-as-a-pilot-project-of-new-hampshire-legal-assistance-it-becomes-a-stand-alone-non-profit-organization-in-1985/) - Since 1986, the New Hampshire Judicial Council (NHJC) is responsible for funding, administering and overseeing statewide indigent defense services. In 1986, NHJC contracts with the non-profit New Hampshire Public Defender to operate the state’s public defender program.
- [The Vermont Office of the Defender General is established.](https://6ac.org/timeline-event/the-vermont-office-of-the-defender-general-is-established/) - Vermont funds and oversees all trial-level indigent defense services through public defender offices and private law firm contracts.
- [The Connecticut Public Defender Services Commission is established.](https://6ac.org/timeline-event/the-connecticut-public-defender-services-commission-is-established/) - All statewide right to counsel services are provided through the Division of Public Defender Services, which includes public defenders and assigned counsel.
- [The Office of the Ohio Public Defender is created.](https://6ac.org/timeline-event/the-office-of-the-ohio-public-defender-is-created/) - Ohio provides state reimbursement of some to the counties for their local indigent defense systems. The Office of the Ohio Public Defender also provides some trial-level representation in serious felony and capital cases to counties opting into the system.
- [Commonwealth of the Northern Mariana Islands Territory created.](https://6ac.org/timeline-event/commonwealth-of-the-northern-mariana-islands-territory-created/)
- [The Office of Public Defender in American Samoa is established.](https://6ac.org/timeline-event/the-office-of-public-defender-in-american-samoa-is-established/) - .
- [The Office of the Public Defender in the Commonwealth of the Northern Mariana Islands is established.](https://6ac.org/timeline-event/the-office-of-the-public-defender-in-the-commonwealth-of-the-northern-mariana-islands-is-established/)
- [The Wyoming Office of the State Public Defender is established.](https://6ac.org/timeline-event/the-wyoming-office-of-the-state-public-defender-is-established/) - Wyoming administers and primarily funds indigent defense services through this statewide executive agency.
- [The Georgia Indigent Defense Council is established.](https://6ac.org/timeline-event/the-georgia-indigent-defense-council-is-established/) - Georgia provides funding and oversight of indigent defense systems through the Georgia Indigent Defense Council. As of 2024, the majority of its judicial circuits have a state-run public defender office.
- [The West Virginia Public Legal Services Council, now known as the West Virginia Public Defender Services, is created.](https://6ac.org/timeline-event/the-west-virginia-public-legal-services-council-now-known-as-the-west-virginia-public-defender-services-is-created/) - West Virginia funds all trial-level indigent defense services. Since 1981, it has created non-profit public defender corporations that serve the majority of its judicial circuits.
- [The Kansas Board of Indigent Defense Services is created.](https://6ac.org/timeline-event/the-kansas-board-of-indigent-defense-services-is-created/) - Kansas funds all trial-level indigent defense services for felony and capital cases. Since 1982, the number of public defender offices increased to 19 trial-level offices and conflict offices.
- [The Massachusetts Committee for Public Counsel Services is established.](https://6ac.org/timeline-event/the-massachusetts-committee-for-public-counsel-services-is-established/) - Massachusetts provides funding, administration, and oversight for all trial-level indigent defense services.
- [U.S. Supreme Court - United States v. Cronic](https://6ac.org/timeline-event/u-s-supreme-court-united-states-v-cronic/) - United States v. Cronic holds that a court should presume that ineffective assistance of counsel will occur at the outset of a case if certain systemic factors are present (or certain systemic factors are absent). The systemic factors that must be present in a public defense system include the early appointment of qualified and trained
- [Massachusetts Supreme Judicial Court rule requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/massachusetts-supreme-judicial-court-rule-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Congress passes the Criminal Justice Act (CJA), establishing a system for appointing private attorneys in the District of Columbia.](https://6ac.org/timeline-event/congress-passes-the-criminal-justice-act-cja-establishing-a-system-for-appointing-private-attorneys-in-the-district-of-columbia/)
- [Minnesota creates a district-by-district public defender system for trial-level indigent representation.](https://6ac.org/timeline-event/minnesota-creates-a-district-by-district-public-defender-system-for-trial-level-indigent-representation/) - After creating Minnesota's district-by-district public defender model, Minnesota creates the Minnesota Board of Public Defense in 1981 and statutorily requires the appointment of district defenders for each of its ten districts.
- [New York's highest court holds that counsel must be appointed in all criminal cases.](https://6ac.org/timeline-event/new-yorks-highest-court-holds-that-counsel-must-be-appointed-in-all-criminal-cases/)
- [Texas law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/texas-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [By ballot initiative, the electors of New Hampshire approve an amendment to the state constitution requiring appointed counsel at state expense in any case that could result in deprivation of liberty.](https://6ac.org/timeline-event/by-ballot-initiative-the-electors-of-new-hampshire-approve-an-amendment-to-the-state-constitution-requiring-appointed-counsel-at-state-expense-in-any-case-that-could-result-in-deprivation-of-liberty/) - "Every person held to answer in any crime or offense punishable by deprivation of liberty shall have the right to counsel at the expense of the state if need is shown…." N.H. Const. pt. 1, art. 15 (1966).
- [The Minnesota Supreme Court holds that counsel must be appointed in all criminal cases.](https://6ac.org/timeline-event/the-minnesota-supreme-court-holds-that-counsel-must-be-appointed-in-all-criminal-cases/) - "In the exercise of our supervisory power to insure the fair administration of justice, we decide that counsel should be provided in any case, whether it be a misdemeanor or not, which may lead to incarceration in a penal institution." State v. Borst, 278 Minn. 388 (1967).
- [The New Jersey's Office of the Public Defender is created.](https://6ac.org/timeline-event/the-new-jerseys-office-of-the-public-defender-is-created/) - New Jersey funds and administers indigent defense services for adult felony and juvenile delinquency cases through the Office of the Public Defender.
- [Guam establishes its first governmental public defender, later to become the Office of the Public Defender and then replaced by the Public Defender Service Corporation.](https://6ac.org/timeline-event/guam-establishes-its-first-governmental-public-defender-later-to-become-the-office-of-the-public-defender-and-then-replaced-by-the-public-defender-service-corporation/)
- [Hawai'i amends its state constitution to require appointment of counsel in any case punishable by imprisonment for more than 60 days.](https://6ac.org/timeline-event/hawaii-amends-its-state-constitution-to-require-appointment-of-counsel-in-any-case-punishable-by-imprisonment-for-more-than-60-days/) - "The State shall provide counsel for an indigent defendant charged with an offense punishable by imprisonment for more than sixty days." Haw. Const. art. I, § 11 (1968).
- [The Alaska Public Defender Act establishes the Public Defender Agency. This is the third statewide, state-funded public defender office in the nation.](https://6ac.org/timeline-event/the-alaska-public-defender-act-establishes-the-public-defender-agency-this-is-the-third-statewide-state-funded-public-defender-office-in-the-nation/) - Alaska establishes the Alaska Public Defender Agency to provide counsel in all state trial-level cases. In 1984, Alaska creates the Office of Public Advocacy to provide conflict representation.
- [The Colorado Office of the State Public Defender is  established. This is the fourth statewide, state-funded public defender office in the nation.](https://6ac.org/timeline-event/the-colorado-office-of-the-state-public-defender-is-established-this-is-the-fourth-statewide-state-funded-public-defender-office-in-the-nation/) - The Colorado State Public Defender provides representation for primary indigent defense services. In 1996, Colorado creates the Office of the Alternate Public Defense Counsel to provide conflict representation.
- [The Public Defender Service of the District of Columbia is established.](https://6ac.org/timeline-event/the-public-defender-service-of-the-district-of-columbia-is-established/)
- [Alabama law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/alabama-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Hawai'i law requires the appointment of counsel in all cases punishable by imprisonment for more than 60 days.](https://6ac.org/timeline-event/hawaii-law-requires-the-appointment-of-counsel-in-all-cases-punishable-by-imprisonment-for-more-than-60-days/) - "Any person charged with an/or found guilty of an offense punishable by imprisonmentt for more than sixty days; and who is financially unable to obtain counsel, shall be entiteld to be represented by a public defender." 1971 Haw. Sess. Laws 390, Act 185.
- [The Maryland Office of Public Defender is established.](https://6ac.org/timeline-event/the-maryland-office-of-public-defender-is-established/) - The state-funded Maryland Office of the Public Defender provides indigent defense services for the entire state through full-time public defenders and conflict panel attorneys.
- [The Rhode Island Supreme Court holds that counsel must be appointed in all cases punishable by more than six months imprisonment.](https://6ac.org/timeline-event/the-rhode-island-supreme-court-holds-that-counsel-must-be-appointed-in-all-cases-punishable-by-more-than-six-months-imprisonment/)
- [The Oregon Supreme Court holds that counsel must be appointed in all criminal cases.](https://6ac.org/timeline-event/the-oregon-supreme-court-holds-that-counsel-must-be-appointed-in-all-criminal-cases/) - "We hold that no person may be deprived of his liberty who has been denied the assistance of counsel as guaranteed by the Sixth Amendment. This holding is applicable to all criminal prosecutions, including prosecutions for violations of municipal ordinances. The denial of the assistance of counsel will preclude the imposition of a jail sentence."
- [Michigan law allows the appointment of counsel in criminal cases, but does not mandate it.](https://6ac.org/timeline-event/michigan-law-allows-the-appointment-of-counsel-in-criminal-cases-but-does-not-mandate-it/)
- [Michigan Supreme Court rule requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/michigan-supreme-court-rule-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Wisconsin law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/wisconsin-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [The Organic Act of Guam establishes the right to counsel in all criminal cases.](https://6ac.org/timeline-event/the-organic-act-of-guam-establishes-the-right-to-counsel-in-all-criminal-cases/)
- [Virginia law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/virginia-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [North Carolina law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/north-carolina-law-requires-the-appointment-of-counsel-in-capital-cases/)
- [New Mexico law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/new-mexico-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [The Revised Organic Act of the Virgin Islands requires that the Sixth Amendment of the U.S. Constitution and the Fourteenth Amendment due process clause apply in the Virgin Islands.](https://6ac.org/timeline-event/the-revised-organic-act-of-the-virgin-islands-requires-that-the-sixth-amendment-of-the-u-s-constitution-and-the-fourteenth-amendment-due-process-clause-apply-in-the-virgin-islands/)
- [The Sociedad para Asistencia Legal de Puerto Rico is founded. This is the first territory public defender office established in the U.S.](https://6ac.org/timeline-event/the-sociedad-para-asistencia-legal-de-puerto-rico-is-founded-this-is-the-first-territory-public-defender-office-established-in-the-u-s/)
- [Maryland court rules require the appointment of counsel in felonies punishable by five or more years imprisonment.](https://6ac.org/timeline-event/maryland-court-rules-require-the-appointment-of-counsel-in-felonies-punishable-by-five-or-more-years-imprisonment/)
- [Massachusetts Supreme Judicial Court rule requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/massachusetts-supreme-judicial-court-rule-requires-the-appointment-of-counsel-in-felony-cases/)
- [Davidson County (Nashville), Tennessee, establishes a public defender office. This is the fifth county public defender office in the nation (the second in Tennessee), and the last one established before Gideon v. Wainwright.](https://6ac.org/timeline-event/davidson-county-nashville-tennessee-establishes-a-public-defender-office-this-is-the-fifth-county-public-defender-office-in-the-nation-the-second-in-tennessee-and-the-last-one-established-befo/)
- [U.S. Supreme Court - Gideon v. Wainwright](https://6ac.org/timeline-event/u-s-supreme-court-gideon-v-wainwright/) - Gideon v. Wainwright clarifies that state are required under the Fourteenth Amendment to provide counsel in felony cases. "[R]eason and reflection, require us to recognize that, in our adversary system of criminal justice, any person haled into court, who is too poor to hire a lawyer, cannot be assured a fair trial unless counsel is
- [Florida establishes a statewide circuit public defender system.](https://6ac.org/timeline-event/florida-establishes-a-statewide-circuit-public-defender-system/) - In the wake of Gideon, Florida creates a state-funded public defender offices in all of its judicial districts. Thirty-four years later, Florida establishes the Office of Criminal Conflict and Civil Regional Counsel to serve as conflict counsel for the public defender's offices (2007).
- [Federal Criminal Justice Act (CJA) creates a system of representing federal criminal defendants, including the Federal Defenders and Managed Assigned Counsel Services, 26 years after Johnson v. Zerbst.](https://6ac.org/timeline-event/federal-criminal-justice-act-cja-creates-a-system-of-representing-federal-criminal-defendants-including-the-federal-defenders-and-managed-assigned-counsel-services-26-years-after-johnson-v-zerbst/)
- [The Delaware Office of the Public Defender is established. The second statewide, state-funded public defender system in the nation.](https://6ac.org/timeline-event/the-delaware-office-of-the-public-defender-is-established-the-second-statewide-state-funded-public-defender-system-in-the-nation/) - Delaware's Office of the Public Defender (OPD) is a state-funded agency providing indigent defense services statewide. In 2011, OPD establishes a new, internal Office of Conflicts Counsel to consolidate conflict assigned counsel systems.
- [End of World War I](https://6ac.org/timeline-event/end-of-world-war-i/)
- [Florida law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/florida-law-requires-the-appointment-of-counsel-in-capital-cases/)
- [Cook County (Chicago), Illinois, establishes a public defender office. This is the third county public defender office in the nation.](https://6ac.org/timeline-event/cook-county-chicago-illinois-establishes-a-public-defender-office-this-is-the-third-county-public-defender-office-in-the-nation/)
- [Douglas County (Omaha), Nebraska, opens its public defender office. This is the fourth county public defender office in the nation.](https://6ac.org/timeline-event/douglas-county-omaha-nebraska-opens-its-public-defender-office-this-is-the-fourth-county-public-defender-office-in-the-nation/)
- [U.S. Supreme Court - Powell v. Alabama](https://6ac.org/timeline-event/u-s-supreme-court-powell-v-alabama/) - Powell v. Alabama clarifies that the right to counsel is the right to effective counsel. It also is holds that counsel is required in capital cases. "The right to be heard would be, in many cases, of little avail if it did not comprehend the right to be heard by counsel. Even the intelligent and
- [New Hampshire law requires the appointment of counsel in felony cases punishable by imprisonment for three or more years.](https://6ac.org/timeline-event/new-hampshire-law-requires-the-appointment-of-counsel-in-felony-cases-punishable-by-imprisonment-for-three-or-more-years/)
- [Oregon law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/oregon-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [U.S. Supreme Court - Johnson v. Zerbst](https://6ac.org/timeline-event/u-s-supreme-court-johnson-v-zerbst/) - Johnson v. Zerbst clarifies that the right to counsel is required in all federal criminal cases. “If the accused, however, is not represented by counsel and has not competently and intelligently waived his constitutional right, the Sixth Amendment stands as a jurisdictional bar to a valid conviction and sentence depriving him of his life or
- [Arizona law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/arizona-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Rhode Island creates the Rhode Island Public Defender. This is the first and only statewide state-funded public defender office established in the nation before Gideon v. Wainwright. The Rhode Island Public Defender handles all criminal case types.](https://6ac.org/timeline-event/rhode-island-creates-the-rhode-island-public-defender-this-is-the-first-and-only-statewide-state-funded-public-defender-office-established-in-the-nation-before-gideon-v-wainwright-the-rhode-island/)
- [Start of World War II](https://6ac.org/timeline-event/start-of-world-war-ii/)
- [The Maryland Supreme Court recognizes in dicta a practice of appointing counsel for indigent defendants in all criminal cases.](https://6ac.org/timeline-event/the-maryland-supreme-court-recognizes-in-dicta-a-practice-of-appointing-counsel-for-indigent-defendants-in-all-criminal-cases/) - Dicta is a comment or observation by the judge in a legal opinion. They are not legally binding but can be cited as persuasive authority. "It has long been the practice in this State for the Court to provide counsel for defendants who face a possibility of life imprisonment, and in all criminal cases in
- [End of World War II](https://6ac.org/timeline-event/end-of-world-war-ii/)
- [The Kentucky Supreme Court holds that counsel must be appointed in felony cases.](https://6ac.org/timeline-event/the-kentucky-supreme-court-holds-that-counsel-must-be-appointed-in-felony-cases/)
- [The Florida Supreme Court recognizes a limited right to appointed counsel in felony cases, but the court has no duty to inform indigent defendants of their right to appointed counsel or inquire as to whether one is desired.](https://6ac.org/timeline-event/the-florida-supreme-court-recognizes-a-limited-right-to-appointed-counsel-in-felony-cases-but-the-court-has-no-duty-to-inform-indigent-defendants-of-their-right-to-appointed-counsel-or-inquire-as-to/) - "It has been the general practice in trial courts in this state, when a party charged with felony has been brought to the bar for arraignment, … If he signified his desire to be represented by counsel, then it has been the practice for the trial judge to appoint some attorney to represent the accused."
- [New Hampshire law requires the appointment of counsel in felony cases punishable by imprisonment for five or more years.](https://6ac.org/timeline-event/new-hampshire-law-requires-the-appointment-of-counsel-in-felony-cases-punishable-by-imprisonment-for-five-or-more-years/) - "[A]nd any person indicted for any other offense, the punishment whereof may be five years' imprisonment, shall be entitled to have counsel assigned to him by the court… if the court shall be of opinion that he is poor and unable to defray the expense of obtaining counsel… and that injustice may be done if
- [Oklahoma law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/oklahoma-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Pennsylvania law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/pennsylvania-law-requires-the-appointment-of-counsel-in-capital-cases-2/)
- [Idaho law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/idaho-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [The Kentucky Supreme Court recognizes in dicta a limited right to appointed counsel in felony cases where defendants are "without education" and cannot properly understand what is at stake.](https://6ac.org/timeline-event/the-kentucky-supreme-court-recognizes-in-dicta-a-limited-right-to-appointed-counsel-in-felony-cases-where-defendants-are-without-education-and-cannot-properly-understand-what-is-at-stake/) - Dicta is a comment or observation by the judge in a legal opinion; it is not legally binding but can be cited as persuasive authority. "We…do not understand the provision of the Constitution and the authorities cited to require the court to appoint counsel for a defendant charged with a felony when he does not
- [Nevada law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/nevada-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [The Legal Aid Society, founded in 1876 to assist low-income people in civil cases (e.g., evictions), expands its mission to provide representation in its first criminal case.](https://6ac.org/timeline-event/the-legal-aid-society-founded-in-1876-to-assist-low-income-people-in-civil-cases-e-g-evictions-expands-its-mission-to-provide-representation-in-its-first-criminal-case/)
- [Alaska Territory created](https://6ac.org/timeline-event/alaska-territory-created/)
- [Los Angeles County establishes a government-staffed public defender office. This is the first county public defender office in the nation.](https://6ac.org/timeline-event/los-angeles-county-establishes-a-government-staffed-public-defender-office-this-is-the-first-county-public-defender-office-in-the-nation/)
- [Portland, Oregon, opens its municipal public defender office. This is the first municipal public defender office in the nation.](https://6ac.org/timeline-event/portland-oregon-opens-its-municipal-public-defender-office-this-is-the-first-municipal-public-defender-office-in-the-nation/)
- [Shelby County (Memphis), Tennessee, establishes a government-staffed public defender office. This is the second county public defender office in the nation and the first public defender office east of the Mississippi.](https://6ac.org/timeline-event/shelby-county-memphis-tennessee-establishes-a-government-staffed-public-defender-office-this-is-the-second-county-public-defender-office-in-the-nation-and-the-first-public-defender-office-east-of/)
- [The Virgin Islands become a U.S. territory.](https://6ac.org/timeline-event/the-virgin-islands-become-a-u-s-territory/)
- [Start of World War I](https://6ac.org/timeline-event/start-of-world-war-i/)
- [Minnesota law requires the appointment of counsel in all serious misdemeanors.](https://6ac.org/timeline-event/minnesota-law-requires-the-appointment-of-counsel-in-all-serious-misdemeanors/)
- [North Dakota law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/north-dakota-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [South Dakota law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/south-dakota-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Oklahoma Territory created](https://6ac.org/timeline-event/oklahoma-territory-created/)
- [Montana law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/montana-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [The Georgia Supreme Court holds that, under the state constitution, counsel must be appointed in all criminal cases.](https://6ac.org/timeline-event/the-georgia-supreme-court-holds-that-under-the-state-constitution-counsel-must-be-appointed-in-all-criminal-cases/) - "Our courts have uniformly adopted the practice of assigning counsel to represent indigent criminals in all cases when they were unable to employ counsel to represent them." Delk v. State, 26 S.E. 752 (Ga. 1896).
- [Guam Territory created](https://6ac.org/timeline-event/guam-territory-created/)
- [Puerto Rico Territory created](https://6ac.org/timeline-event/puerto-rico-territory-created/)
- [Hawai'i Territory created](https://6ac.org/timeline-event/hawaii-territory-created/)
- [Puerto Rico law establishes the right to counsel in all criminal cases.](https://6ac.org/timeline-event/puerto-rico-law-establishes-the-right-to-counsel-in-all-criminal-cases/)
- [Puerto Rico law requires the appointment of counsel in capital or life imprisonment cases.](https://6ac.org/timeline-event/puerto-rico-law-requires-the-appointment-of-counsel-in-capital-or-life-imprisonment-cases/) - “When the accused is brought before the court for the purpose of arraigning him on a charge involving capital punishment or life imprisonment, if it should appear that he has no counsel and that the poverty of the accused does not permit him to employ a defence, the court shall appoint one or more practising
- [Montana Territory law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/montana-territory-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [New York courts, in practice, assign counsel to indigent defendants in criminal cases, prior to any applicable statute.](https://6ac.org/timeline-event/new-york-courts-in-practice-assign-counsel-to-indigent-defendants-in-criminal-cases-prior-to-any-applicable-statute/) - "Courts have uniformly assigned counsel to defend prisoners who had not the ability to procure counsel." People ex rel. Hadley v. Albany Cnty. Sup'rs, 1864 WL 3592 (N.Y. Sup. Ct. 1864).
- [End of Civil War](https://6ac.org/timeline-event/end-of-civil-war/)
- [Fourteenth Amendment Ratified](https://6ac.org/timeline-event/fourteenth-amendment-ratified/) - The 14th Amendment of the U.S. Constitution states, in part: "… nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.” The right to due process of law and equal protection were now declared
- [Wyoming Territory created](https://6ac.org/timeline-event/wyoming-territory-created/)
- [Minnesota law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/minnesota-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Maine law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/maine-law-requires-the-appointment-of-counsel-in-capital-cases/) - "Competent counsel shall be assigned by the court in capital cases, when it appears that the accused has not sufficient means to employ counsel, and reasonable compensation shall be allowed by the court, to be paid out of the state treasury." The Revised Statutes of the State of Maine, Ch. 134, § 14 (1871).
- [Nebraska law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/nebraska-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [The North Carolina Supreme Court states in dicta that court must appoint counsel for indigent defendants in all criminal cases.](https://6ac.org/timeline-event/the-north-carolina-supreme-court-states-in-dicta-that-court-must-appoint-counsel-for-indigent-defendants-in-all-criminal-cases/) - Dicta is a comment or observation by the judge in a legal opinion; it is not legally binding but can be cited as persuasive authority. "In this country every one has a constitutional right in all criminal prosecutions to have counsel for his defence; and if he be too poor to employ counsel, it is
- [Recognizing a custom of appointing counsel to indigent defendants who request one, the Nevada Legislature passes a law providing for compensation for appointed counsel.](https://6ac.org/timeline-event/recognizing-a-custom-of-appointing-counsel-to-indigent-defendants-who-request-one-the-nevada-legislature-passes-a-law-providing-for-compensation-for-appointed-counsel/) - "An attorney appointed by a Court to defend a person indicted for any offense, is entitled to receive from the County treasury the following fees…" Assembly Bill 122, § 1 (1875).
- [Wyoming Territory law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/wyoming-territory-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [The Nevada Supreme Court states in dicta that the failure to appoint counsel is reversible error.](https://6ac.org/timeline-event/the-nevada-supreme-court-states-in-dicta-that-the-failure-to-appoint-counsel-is-reversible-error/) - Dicta is a comment or observation by the judge in a legal opinion; it is not legally binding but can be cited as persuasive authority. "In many of the states, perhaps in most of them, the judges of the courts of record are required by statute to assign counsel to poor defendants, and in all
- [Indiana law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/indiana-law-requires-the-appointment-of-counsel-in-all-criminal-cases-2/)
- [New York law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/new-york-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Tennessee law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/tennessee-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [New Mexico Territory created](https://6ac.org/timeline-event/new-mexico-territory-created/)
- [Utah Territory created](https://6ac.org/timeline-event/utah-territory-created/)
- [The Wisconsin Supreme Court holds that counsel must be appointed in felony cases.](https://6ac.org/timeline-event/the-wisconsin-supreme-court-holds-that-counsel-must-be-appointed-in-felony-cases/) - "Suppose a man too poor to retain counsel to be put upon trial for an offence involving his liberty for life; the constitution declares that he shall enjoy the right to be heard by himself and counsel. He is entitled to have compulsory process to compel the attendance of witnesses; they are to be sworn
- [Iowa law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/iowa-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Start of Civil War](https://6ac.org/timeline-event/start-of-civil-war/)
- [Colorado Territory created](https://6ac.org/timeline-event/colorado-territory-created/)
- [Nevada Territory created](https://6ac.org/timeline-event/nevada-territory-created/)
- [Dakota Territory (North Dakota and South Dakota) created](https://6ac.org/timeline-event/dakota-territory-north-dakota-and-south-dakota-created/)
- [Kansas law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/kansas-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Arizona Territory created](https://6ac.org/timeline-event/arizona-territory-created/)
- [Idaho Territory created](https://6ac.org/timeline-event/idaho-territory-created/)
- [Dakota Territory law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/dakota-territory-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - The law applies to both North Dakota and South Dakota.
- [Montana Territory created](https://6ac.org/timeline-event/montana-territory-created/)
- [Oregon Territory created](https://6ac.org/timeline-event/oregon-territory-created/)
- [Minnesota Territory created](https://6ac.org/timeline-event/minnesota-territory-created/)
- [Delaware law requires the appointment of counsel in capital cases and in certain serious felonies.](https://6ac.org/timeline-event/delaware-law-requires-the-appointment-of-counsel-in-capital-cases-and-in-certain-serious-felonies/)
- [Washington Territory created](https://6ac.org/timeline-event/washington-territory-created/)
- [Kansas Territory created](https://6ac.org/timeline-event/kansas-territory-created/)
- [Nebraska Territory created](https://6ac.org/timeline-event/nebraska-territory-created/)
- [The Georgia Supreme Court states in dicta that the law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/the-georgia-supreme-court-states-in-dicta-that-the-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - Dicta is a comment or observation by the judge in a legal opinion; it is not legally binding but can be cited as persuasive authority. "It is true, that, in our State, no man, white or black, bond or free, can be tried without the assistance of counsel, as the humane provisions of our law
- [The Indiana Supreme Court recognizes a right to appointed counsel, grounded in "the principles of a civilized society."](https://6ac.org/timeline-event/the-indiana-supreme-court-recognizes-a-right-to-appointed-counsel-grounded-in-the-principles-of-a-civilized-society/) - "It is not to be thought of, in a civilized community, for a moment, that any citizen put in jeopardy of life or liberty, should be debarred of counsel because he was too poor to employ such aid. No Court could be respected, or respect itself, to sit and hear such a trial. The defense
- [Washington Territory law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/washington-territory-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Kansas Territory law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/kansas-territory-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Texas law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/texas-law-requires-the-appointment-of-counsel-in-capital-cases/)
- [The 1818 Connecticut Constitution includes a right to counsel, which is interpreted as requiring the appointment of counsel due to the state's established practice since the 1700s.](https://6ac.org/timeline-event/the-1818-connecticut-constitution-includes-a-right-to-counsel-which-is-interpreted-as-requiring-the-appointment-of-counsel-due-to-the-states-established-practice-since-the-1700s/)
- [When Illinois becomes a state in 1818, the legislature reenacts the territory law that requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/when-illinois-becomes-a-state-in-1818-the-legislature-reenacts-the-territory-law-that-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Missouri Territory law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/missouri-territory-law-requires-the-appointment-of-counsel-in-felony-cases/) - Until 1819, Arkansas is part of the Missouri Territory. Until 1821, Colorado, Iowa, Kansas, parts of Minnesota, Montana, Nebraska, North Dakota, Oklahoma, South Dakota, and Wyoming are part of the territory. New Mexico is part of it until 1850.
- [Arkansas Territory created](https://6ac.org/timeline-event/arkansas-territory-created/)
- [Florida Territory created](https://6ac.org/timeline-event/florida-territory-created/)
- [Mississippi law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/mississippi-law-requires-the-appointment-of-counsel-in-capital-cases/)
- [Alabama law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/alabama-law-requires-the-appointment-of-counsel-in-capital-cases/)
- [Missouri law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/missouri-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Wisconsin Territory created](https://6ac.org/timeline-event/wisconsin-territory-created/)
- [Michigan Territory law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/michigan-territory-law-requires-the-appointment-of-counsel-in-all-criminal-cases/) - "And be it further enacted, That the court before whom any person shall be tried, upon indictment, is hereby authorised and requested [required] to assign to such person, if not of ability to procure counsel, such counsel, not exceeding two, as he or she shall desire, to whom such counsel shall have access at all
- [Iowa Territory created](https://6ac.org/timeline-event/iowa-territory-created/)
- [Indiana law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/indiana-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Mississippi Territory created](https://6ac.org/timeline-event/mississippi-territory-created/)
- [Rhode Island law allows for the right to counsel in criminal cases, but does not mandate it.](https://6ac.org/timeline-event/rhode-island-law-allows-for-the-right-to-counsel-in-criminal-cases-but-does-not-mandate-it/)
- [Indiana Territory created](https://6ac.org/timeline-event/indiana-territory-created/)
- [Louisiana Purchase. This is a significant expansion of the United States and the new territory is subject to federal law, including the right to counsel.](https://6ac.org/timeline-event/louisiana-purchase-this-is-a-significant-expansion-of-the-united-states-and-the-new-territory-is-subject-to-federal-law-including-the-right-to-counsel/)
- [Louisiana Territory created](https://6ac.org/timeline-event/louisiana-territory-created/)
- [The Territory of New Orleans statutorily requires the appointment of counsel in cases with seven or more years of imprisonment as a possible sentence.](https://6ac.org/timeline-event/the-territory-of-new-orleans-statutorily-requires-the-appointment-of-counsel-in-cases-with-seven-or-more-years-of-imprisonment-as-a-possible-sentence/)
- [Michigan Territory created](https://6ac.org/timeline-event/michigan-territory-created/)
- [Illinois Territory created](https://6ac.org/timeline-event/illinois-territory-created/)
- [The practice of appointing counsel to indigent defendants in all cases was in force before the Territory of Illinois was established and is incorporated into the territory's laws upon becoming a territory in 1809.](https://6ac.org/timeline-event/the-practice-of-appointing-counsel-to-indigent-defendants-in-all-cases-was-in-force-before-the-territory-of-illinois-was-established-and-is-incorporated-into-the-territorys-laws-upon-becoming-a-terri/)
- [Indiana Territory law requires the appointment of counsel in all criminal cases.](https://6ac.org/timeline-event/indiana-territory-law-requires-the-appointment-of-counsel-in-all-criminal-cases/)
- [Ohio law requires the appointment of counsel in felony cases.](https://6ac.org/timeline-event/ohio-law-requires-the-appointment-of-counsel-in-felony-cases/)
- [Missouri Territory created](https://6ac.org/timeline-event/missouri-territory-created/)
- [Alabama Territory created](https://6ac.org/timeline-event/alabama-territory-created/)
- [U.S. Constitution Ratified](https://6ac.org/timeline-event/u-s-constitution-ratified/)
- [Maryland statehood; State Constitution in effect since 1776](https://6ac.org/timeline-event/maryland-statehood-state-constitution-in-effect-since-1776/) - Article XIX: "That, in all criminal prosecutions, every man hath a right … to be allowed counsel."
- [Virginia statehood; State Constitution in effect since 1776](https://6ac.org/timeline-event/virginia-statehood-state-constitution-in-effect-since-1776/) - The Virginia Constitution make no mention of a right to counsel for the accused.
- [Ohio Territory created](https://6ac.org/timeline-event/ohio-territory-created/)
- [Federal Criminal Justice Act of 1790](https://6ac.org/timeline-event/federal-criminal-justice-act-of-1790/) - "Every person who is indicted of treason or other capital crime, shall be allowed to make his full defense by counsel learned in the law; and the court before which he is tried, or some judge thereof, shall immediately, upon his request, assign to him such counsel not exceeding two, as he may desire, and
- [Tennessee Territory created](https://6ac.org/timeline-event/tennessee-territory-created/)
- [District of Columbia created](https://6ac.org/timeline-event/district-of-columbia-created/)
- [Bill of Rights, including Sixth Amendment, ratified](https://6ac.org/timeline-event/bill-of-rights-including-sixth-amendment-ratified/) - “In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district wherein the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted
- [Vermont statehood; State Constitution in effect since 1777](https://6ac.org/timeline-event/vermont-statehood-state-constitution-in-effect-since-1777/) - Article X: "That, in all prosecutions for criminal offences, a man hath a right to be heard, by himself and his counsel."
- [William Penn, the proprietor of the colony of Pennsylvania, issues a Charter of Privileges, which provides that “all Criminalls shall have the same Priviledges of Wittnesses and Councill as theire Prosecutors.”](https://6ac.org/timeline-event/william-penn-the-proprietor-of-the-colony-of-pennsylvania-issues-a-charter-of-privileges-which-provides-that-all-criminalls-shall-have-the-same-priviledges-of-wittnesses-and-councill-as-th/) - Some historians argue this is the first colonial enactment explicitly recognizing a right to counsel in felony cases. Pennsylvania was previously governed by English law, which limited the role of attorneys in felony cases.
- [The Delaware charter of 1701 includes a right to counsel in all criminal cases.](https://6ac.org/timeline-event/the-delaware-charter-of-1701-includes-a-right-to-counsel-in-all-criminal-cases/) - "That all Criminals shall have the same Privileges of Witnesses and Council as their Prosecutors." Del. Charter 1701, art. 1, § 5.
- [Counsel appears for defendants in piracy cases in Massachusetts as early as 1704.](https://6ac.org/timeline-event/counsel-appears-for-defendants-in-piracy-cases-in-massachusetts-as-early-as-1704/)
- [Delaware law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/delaware-law-requires-the-appointment-of-counsel-in-capital-cases/) - "And that upon all trials of the said capital crimes, lawful challenges shall be allowed, and learned council assigned to the prisoners…." Laws of the State of Delaware, Ch. XXIIa, § 4 (1719).
- [Virginia law requires the appointment of counsel in capital cases.](https://6ac.org/timeline-event/virginia-law-requires-the-appointment-of-counsel-in-capital-cases/) - Virginia law applies to West Virginia until it becomes a state in 1863.
- [As early as 1750, the custom in Connecticut and New Jersey is to appoint counsel if the accused requests assistance.](https://6ac.org/timeline-event/as-early-as-1750-the-custom-in-connecticut-and-new-jersey-is-to-appoint-counsel-if-the-accused-requests-assistance/)
- [The 1776 Delaware Constitution continues previous statutes in force, including the right to appointed counsel in capital cases. In addition, the 1776 Declaration of Rights and Fundamental Rules of the Delaware State includes a right to counsel.](https://6ac.org/timeline-event/the-1776-delaware-constitution-continues-previous-statutes-in-force-including-the-right-to-appointed-counsel-in-capital-cases-in-addition-the-1776-declaration-of-rights-and-fundamental-rules-of-the/) - "That in all prosecutions for criminal offences, every man hath a right… to be allowed counsel." Declaration of Rights and Fundamental Rules of the Delaware State, § 14 (1776).
- [New Hampshire law requires the appointment of counsel in cases of treason.](https://6ac.org/timeline-event/new-hampshire-law-requires-the-appointment-of-counsel-in-cases-of-treason/) - "And be it further enacted by the Authority aforesaid that every person whatsoever that shall be accused and indicted for Treason, or for Misprision of Treason shall … be admitted to make his or their defence by Counsel learned in the Law which, if requested, the Court shall assign him or them, to whom such
- [End of Revolutionary War](https://6ac.org/timeline-event/end-of-revolutionary-war/)
- [Virginia law allows for the right to counsel in criminal cases, but does not mandate it.](https://6ac.org/timeline-event/virginia-law-allows-for-the-right-to-counsel-in-criminal-cases-but-does-not-mandate-it/)
- [New Jersey statehood; State Constitution in effect since 1776](https://6ac.org/timeline-event/new-jersey-statehood-state-constitution-in-effect-since-1776/) - Article XVI: "That all Criminals shall be admitted to the same Privileges of Witnesses & Counsel, as their Prosecutors are or shall be entitled to."

## Timeline Map

- [AA ALL STATES - 1972](https://6ac.org/timeline-map/aa-all-states-1972/)
- [Rhode Island - 1971](https://6ac.org/timeline-map/rhode-island-1971/)
- [Alabama - 1971](https://6ac.org/timeline-map/alabama-1971/)
- [Hawai'i - 1968](https://6ac.org/timeline-map/hawaii-1968/)
- [Minnesota - 1967](https://6ac.org/timeline-map/minnesota-1967/)
- [Texas - 1966](https://6ac.org/timeline-map/texas-1966/)
- [New Hampshire - 1966](https://6ac.org/timeline-map/new-hampshire-1966/)
- [North Carolina - 1943](https://6ac.org/timeline-map/north-carolina-1943/)
- [Kentucky - 1948](https://6ac.org/timeline-map/kentucky-1948/)
- [Arizona - 1939](https://6ac.org/timeline-map/arizona-1939/)
- [Oregon - 1937](https://6ac.org/timeline-map/oregon-1937/)
- [New Hampshire - 1937](https://6ac.org/timeline-map/new-hampshire-1937/)
- [West Virginia - 1936](https://6ac.org/timeline-map/west-virginia-1936/)
- [Puerto Rico - 1935](https://6ac.org/timeline-map/puerto-rico-1935/)
- [AA ALL STATES - 1932](https://6ac.org/timeline-map/aa-all-states-1932/)
- [Florida - 1927](https://6ac.org/timeline-map/florida-1927/)
- [Hawai'i - 1919](https://6ac.org/timeline-map/hawaii-1919/)
- [Connecticut - 1917](https://6ac.org/timeline-map/connecticut-1917/)
- [Virginia - 1950](https://6ac.org/timeline-map/virginia-1950/)
- [New Mexico - 1953](https://6ac.org/timeline-map/new-mexico-1953/)
- [Maryland - 1956](https://6ac.org/timeline-map/maryland-1956/)
- [Massachusetts - 1958](https://6ac.org/timeline-map/massachusetts-1958/)
- [Alaska - 1959](https://6ac.org/timeline-map/alaska-1959/)
- [Texas - 1959](https://6ac.org/timeline-map/texas-1959/)
- [AA ALL STATES - 1963](https://6ac.org/timeline-map/aa-all-states-1963/)
- [Massachusetts - 1964](https://6ac.org/timeline-map/massachusetts-1964/)
- [New York - 1965](https://6ac.org/timeline-map/new-york-1965/)
- [New York - 1881](https://6ac.org/timeline-map/new-york-1881/)
- [Neada - 1909](https://6ac.org/timeline-map/neada-1909/)
- [Idaho - 1908](https://6ac.org/timeline-map/idaho-1908/)
- [Puerto Rico - 1905](https://6ac.org/timeline-map/puerto-rico-1905/)
- [Georgia - 1896](https://6ac.org/timeline-map/georgia-1896/)
- [Montana - 1895](https://6ac.org/timeline-map/montana-1895/)
- [Oklahoma - 1890](https://6ac.org/timeline-map/oklahoma-1890/)
- [Utah - 1878](https://6ac.org/timeline-map/utah-1878/)
- [Texas - 1856](https://6ac.org/timeline-map/texas-1856/)
- [Illinois - 1857](https://6ac.org/timeline-map/illinois-1857/)
- [Tennessee - 1858](https://6ac.org/timeline-map/tennessee-1858/)
- [Wisconsin - 1859](https://6ac.org/timeline-map/wisconsin-1859/)
- [North Dakota - 1863](https://6ac.org/timeline-map/north-dakota-1863/)
- [South Dakota - 1863](https://6ac.org/timeline-map/south-dakota-1863/)
- [Montana - 1864](https://6ac.org/timeline-map/montana-1864/)
- [Minnesota - 1869](https://6ac.org/timeline-map/minnesota-1869/)
- [Maine - 1871](https://6ac.org/timeline-map/maine-1871/)
- [California - 1872](https://6ac.org/timeline-map/california-1872/)
- [Nebraska - 1873](https://6ac.org/timeline-map/nebraska-1873/)
- [Wyoming - 1876](https://6ac.org/timeline-map/wyoming-1876/)
- [Pennsylvania - 1718](https://6ac.org/timeline-map/pennsylvania-1718/)
- [Delaware - 1718](https://6ac.org/timeline-map/delaware-1718/)
- [South Carolina - 1731](https://6ac.org/timeline-map/south-carolina-1731/)
- [Virginia - 1734](https://6ac.org/timeline-map/virginia-1734/)
- [West Virginia - 1734](https://6ac.org/timeline-map/west-virginia-1734/)
- [New Hampshire - 1791](https://6ac.org/timeline-map/new-hampshire-1791/)
- [New Jersey - 1795](https://6ac.org/timeline-map/new-jersey-1795/)
- [Louisiana - 1804](https://6ac.org/timeline-map/louisiana-1804/)
- [Alabama - 1807](https://6ac.org/timeline-map/alabama-1807/)
- [Mississippi - 1807](https://6ac.org/timeline-map/mississippi-1807/)
- [Arkansas - 1808](https://6ac.org/timeline-map/arkansas-1808/)
- [Indiana - 1809](https://6ac.org/timeline-map/indiana-1809/)
- [Ohio - 1809](https://6ac.org/timeline-map/ohio-1809/)
- [Missouri - 1818](https://6ac.org/timeline-map/missouri-1818/)
- [Michigan - 1820](https://6ac.org/timeline-map/michigan-1820/)
- [Arkansas - 1838](https://6ac.org/timeline-map/arkansas-1838/)
- [Iowa - 1839](https://6ac.org/timeline-map/iowa-1839/)
- [Delaware - 1852](https://6ac.org/timeline-map/delaware-1852/)
- [Washington - 1854](https://6ac.org/timeline-map/washington-1854/)
- [Kansas - 1855](https://6ac.org/timeline-map/kansas-1855/)

## Categories

- [Pleading The Sixth](https://6ac.org/category/pleading-the-sixth/)
- [Uncategorized](https://6ac.org/category/uncategorized/)

## Tags

- [funding](https://6ac.org/tag/funding/)
- [pennsylvania](https://6ac.org/tag/pennsylvania/)
- [south dakota](https://6ac.org/tag/south-dakota/)
- [ten principles](https://6ac.org/tag/ten-principles/)
- [assigned counsel - compensation](https://6ac.org/tag/assigned-counsel-compensation/)
- [conflicts](https://6ac.org/tag/conflicts/)
- [Virginia](https://6ac.org/tag/virginia/)
- [accountability](https://6ac.org/tag/accountability/)
- [assigned counsel](https://6ac.org/tag/assigned-counsel/)
- [contracts - flat fee](https://6ac.org/tag/contracts-flat-fee/)
- [criminal justice reform](https://6ac.org/tag/criminal-justice-reform/)
- [independence](https://6ac.org/tag/independence/)
- [independence - judicial interference](https://6ac.org/tag/independence-judicial-interference/)
- [independence - political interference](https://6ac.org/tag/independence-political-interference/)
- [Oregon](https://6ac.org/tag/oregon/)
- [oversight](https://6ac.org/tag/oversight/)
- [pleading the sixth](https://6ac.org/tag/pleading-the-sixth/)
- [public defender office](https://6ac.org/tag/public-defender-office/)
- [supervision](https://6ac.org/tag/supervision/)
- [New Jersey](https://6ac.org/tag/new-jersey/)
- [recoupment](https://6ac.org/tag/recoupment/)
- [reimbursement fees](https://6ac.org/tag/reimbursement-fees/)
- [DOJ](https://6ac.org/tag/doj/)
- [federal](https://6ac.org/tag/federal/)
- [GAO](https://6ac.org/tag/gao/)
- [national](https://6ac.org/tag/national/)
- [standards](https://6ac.org/tag/standards/)
- [standards - system](https://6ac.org/tag/standards-system/)
- [Michigan](https://6ac.org/tag/michigan/)
- [bail](https://6ac.org/tag/bail/)
- [early appointment of counsel](https://6ac.org/tag/early-appointment-of-counsel/)
- [first appearance](https://6ac.org/tag/first-appearance/)
- [litigation - systemic](https://6ac.org/tag/litigation-systemic/)
- [Maryland](https://6ac.org/tag/maryland/)
- [Nevada](https://6ac.org/tag/nevada/)
- [contracts](https://6ac.org/tag/contracts/)
- [Florida](https://6ac.org/tag/florida/)
- [caseloads & workloads](https://6ac.org/tag/caseloads-workloads/)
- [Missouri](https://6ac.org/tag/missouri/)
- [legislation](https://6ac.org/tag/legislation/)
- [juvenile delinquencies & status offenses](https://6ac.org/tag/juvenile-delinquencies-status-offenses/)
- [Memphis TN](https://6ac.org/tag/memphis-tn/)
- [Shelby County TN](https://6ac.org/tag/shelby-county-tn/)
- [Tennessee](https://6ac.org/tag/tennessee/)
- [Mississippi](https://6ac.org/tag/mississippi/)
- [over-incarceration](https://6ac.org/tag/over-incarceration/)
- [commissions](https://6ac.org/tag/commissions/)
- [county systems](https://6ac.org/tag/county-systems/)
- [North Dakota](https://6ac.org/tag/north-dakota/)
- [Louisiana](https://6ac.org/tag/louisiana/)
- [caseloads - weighted caseload studies](https://6ac.org/tag/caseloads-weighted-caseload-studies/)
- [New Mexico](https://6ac.org/tag/new-mexico/)
- [Texas](https://6ac.org/tag/texas/)
- [Harris County TX](https://6ac.org/tag/harris-county-tx/)
- [Wichita County TX](https://6ac.org/tag/wichita-county-tx/)
- [Indiana](https://6ac.org/tag/indiana/)
- [Putnam County IN](https://6ac.org/tag/putnam-county-in/)
- [rural areas](https://6ac.org/tag/rural-areas/)
- [King County WA](https://6ac.org/tag/king-county-wa/)
- [parity](https://6ac.org/tag/parity/)
- [Seattle WA](https://6ac.org/tag/seattle-wa/)
- [Washington](https://6ac.org/tag/washington/)
- [Eric Holder](https://6ac.org/tag/eric-holder/)
- [international](https://6ac.org/tag/international/)
- [United Nations](https://6ac.org/tag/united-nations/)
- [denial of right to counsel](https://6ac.org/tag/denial-of-right-to-counsel/)
- [Rothgery v. Gillespie County](https://6ac.org/tag/rothgery-v-gillespie-county/)
- [United States v. Cronic](https://6ac.org/tag/united-states-v-cronic/)
- [Williamson County TX](https://6ac.org/tag/williamson-county-tx/)
- [Austin TX](https://6ac.org/tag/austin-tx/)
- [judiciary](https://6ac.org/tag/judiciary/)
- [Travis County TX](https://6ac.org/tag/travis-county-tx/)
- [task force](https://6ac.org/tag/task-force/)
- [Alabama v. Shelton](https://6ac.org/tag/alabama-v-shelton/)
- [ethical duties](https://6ac.org/tag/ethical-duties/)
- [Idaho](https://6ac.org/tag/idaho/)
- [indigency - criteria](https://6ac.org/tag/indigency-criteria/)
- [waiver of right to counsel](https://6ac.org/tag/waiver-of-right-to-counsel/)
- [compensation & expenses](https://6ac.org/tag/compensation-expenses/)
- [Maine](https://6ac.org/tag/maine/)
- [Alabama](https://6ac.org/tag/alabama/)
- [Jefferson County AL](https://6ac.org/tag/jefferson-county-al/)
- [Montgomery County AL](https://6ac.org/tag/montgomery-county-al/)
- [case law - US Supreme Court](https://6ac.org/tag/case-law-us-supreme-court/)
- [history](https://6ac.org/tag/history/)
- [Powell v. Alabama](https://6ac.org/tag/powell-v-alabama/)
- [U.S. Congress](https://6ac.org/tag/u-s-congress/)
- [Canyon County ID](https://6ac.org/tag/canyon-county-id/)
- [Lander County NV](https://6ac.org/tag/lander-county-nv/)
- [reports](https://6ac.org/tag/reports/)
- [Shepherd L. Wixom](https://6ac.org/tag/shepherd-l-wixom/)
- [Sixth Amendment Center](https://6ac.org/tag/sixth-amendment-center/)
- [Anthony Lewis](https://6ac.org/tag/anthony-lewis/)
- [Gideon's Trumpet](https://6ac.org/tag/gideons-trumpet/)
- [audio](https://6ac.org/tag/audio/)
- [podcast](https://6ac.org/tag/podcast/)
- [Berrien County MI](https://6ac.org/tag/berrien-county-mi/)
- [case law - state courts](https://6ac.org/tag/case-law-state-courts/)
- [Genesee County MI](https://6ac.org/tag/genesee-county-mi/)
- [Muskegon County MI](https://6ac.org/tag/muskegon-county-mi/)
- [Strickland v. Washington](https://6ac.org/tag/strickland-v-washington/)
- [chief public defenders](https://6ac.org/tag/chief-public-defenders/)
- [White House](https://6ac.org/tag/white-house/)
- [litigation](https://6ac.org/tag/litigation/)
- [Miami-Dade County FL](https://6ac.org/tag/miami-dade-county-fl/)
- [ACLU](https://6ac.org/tag/aclu/)
- [Burlington WA](https://6ac.org/tag/burlington-wa/)
- [Mount Vernon WA](https://6ac.org/tag/mount-vernon-wa/)
- [municipal systems](https://6ac.org/tag/municipal-systems/)
- [California](https://6ac.org/tag/california/)
- [Fresno County CA](https://6ac.org/tag/fresno-county-ca/)
- [Seattle University School of Law](https://6ac.org/tag/seattle-university-school-of-law/)
- [Eight Guidelines](https://6ac.org/tag/eight-guidelines/)
- [Helena MT](https://6ac.org/tag/helena-mt/)
- [Lewis & Clark County MT](https://6ac.org/tag/lewis-clark-county-mt/)
- [Montana](https://6ac.org/tag/montana/)
- [plea bargaining - early case resolution](https://6ac.org/tag/plea-bargaining-early-case-resolution/)
- [Reno NV](https://6ac.org/tag/reno-nv/)
- [Washoe County NV](https://6ac.org/tag/washoe-county-nv/)
- [St. Louis County MO](https://6ac.org/tag/st-louis-county-mo/)
- [training](https://6ac.org/tag/training/)
- [case law - federal courts](https://6ac.org/tag/case-law-federal-courts/)
- [Delaware](https://6ac.org/tag/delaware/)
- [evaluations of systems](https://6ac.org/tag/evaluations-of-systems/)
- [state systems](https://6ac.org/tag/state-systems/)
- [Fred Friedman](https://6ac.org/tag/fred-friedman/)
- [Minnesota](https://6ac.org/tag/minnesota/)
- [Dennis Keefe](https://6ac.org/tag/dennis-keefe/)
- [Lancaster County NE](https://6ac.org/tag/lancaster-county-ne/)
- [Nebraska](https://6ac.org/tag/nebraska/)
- [critical stages of a case](https://6ac.org/tag/critical-stages-of-a-case/)
- [pretrial detention](https://6ac.org/tag/pretrial-detention/)
- [death penalty cases](https://6ac.org/tag/death-penalty-cases/)
- [Wyoming](https://6ac.org/tag/wyoming/)
- [Bill Leahy](https://6ac.org/tag/bill-leahy/)
- [Conference of Chief Justices](https://6ac.org/tag/conference-of-chief-justices/)
- [Conference of State Court Administrators](https://6ac.org/tag/conference-of-state-court-administrators/)
- [Scott County MS](https://6ac.org/tag/scott-county-ms/)
- [denial of right to counsel - constructive](https://6ac.org/tag/denial-of-right-to-counsel-constructive/)
- [New York](https://6ac.org/tag/new-york/)
- [Onondaga County NY](https://6ac.org/tag/onondaga-county-ny/)
- [Ontario County NY](https://6ac.org/tag/ontario-county-ny/)
- [Schuyler County NY](https://6ac.org/tag/schuyler-county-ny/)
- [Suffolk County NY](https://6ac.org/tag/suffolk-county-ny/)
- [Washington County NY](https://6ac.org/tag/washington-county-ny/)
- [video](https://6ac.org/tag/video/)
- [Forsyth County NC](https://6ac.org/tag/forsyth-county-nc/)
- [North Carolina](https://6ac.org/tag/north-carolina/)
- [Winston-Salem NC](https://6ac.org/tag/winston-salem-nc/)
- [ABA](https://6ac.org/tag/aba/)
- [prosecution](https://6ac.org/tag/prosecution/)
- [South Carolina](https://6ac.org/tag/south-carolina/)
- [Tigran Eldred](https://6ac.org/tag/tigran-eldred/)
- [Ben Hill County GA](https://6ac.org/tag/ben-hill-county-ga/)
- [Crisp County GA](https://6ac.org/tag/crisp-county-ga/)
- [Dooly County GA](https://6ac.org/tag/dooly-county-ga/)
- [Georgia](https://6ac.org/tag/georgia/)
- [Wilcox County GA](https://6ac.org/tag/wilcox-county-ga/)
- [Wisconsin](https://6ac.org/tag/wisconsin/)
- [Chuck Grassley](https://6ac.org/tag/chuck-grassley/)
- [U.S. Senate Judiciary Committee](https://6ac.org/tag/u-s-senate-judiciary-committee/)
- [misdemeanors](https://6ac.org/tag/misdemeanors/)
- [Argersinger v. Hamlin](https://6ac.org/tag/argersinger-v-hamlin/)
- [Utah](https://6ac.org/tag/utah/)
- [tribal](https://6ac.org/tag/tribal/)
- [Luzerne County PA](https://6ac.org/tag/luzerne-county-pa/)
- [Ohio](https://6ac.org/tag/ohio/)
- [appeals](https://6ac.org/tag/appeals/)
- [judiciary - non-lawyer judges](https://6ac.org/tag/judiciary-non-lawyer-judges/)
- [chief public defenders - elected](https://6ac.org/tag/chief-public-defenders-elected/)
- [Grays Harbor County WA](https://6ac.org/tag/grays-harbor-county-wa/)
- [Logan County WV](https://6ac.org/tag/logan-county-wv/)
- [West Virginia](https://6ac.org/tag/west-virginia/)
- [Guam](https://6ac.org/tag/guam/)
- [qualifications of attorneys](https://6ac.org/tag/qualifications-of-attorneys/)
- [U.S. territories](https://6ac.org/tag/u-s-territories/)
- [Virgin Islands](https://6ac.org/tag/virgin-islands/)
- [commission](https://6ac.org/tag/commission/)
- [David Carroll](https://6ac.org/tag/david-carroll/)
- [Politico](https://6ac.org/tag/politico/)
- [The Marshall Project](https://6ac.org/tag/the-marshall-project/)
- [attorney disciplinary proceedings](https://6ac.org/tag/attorney-disciplinary-proceedings/)
- [Detroit MI](https://6ac.org/tag/detroit-mi/)
- [Wayne County MI](https://6ac.org/tag/wayne-county-mi/)
- [federal defenders](https://6ac.org/tag/federal-defenders/)
- [multi-county systems](https://6ac.org/tag/multi-county-systems/)
- [continuous representation by same attorney](https://6ac.org/tag/continuous-representation-by-same-attorney/)
- [indigency - who determines](https://6ac.org/tag/indigency-who-determines/)
- [Amarillo TX](https://6ac.org/tag/amarillo-tx/)
- [Armstrong County TX](https://6ac.org/tag/armstrong-county-tx/)
- [denial of right to counsel - actual](https://6ac.org/tag/denial-of-right-to-counsel-actual/)
- [Potter County TX](https://6ac.org/tag/potter-county-tx/)
- [Massachusetts](https://6ac.org/tag/massachusetts/)
- [Santa Cruz County CA](https://6ac.org/tag/santa-cruz-county-ca/)
- [Illinois](https://6ac.org/tag/illinois/)
- [Arizona](https://6ac.org/tag/arizona/)
- [Arkansas](https://6ac.org/tag/arkansas/)
- [Colorado](https://6ac.org/tag/colorado/)
- [Connecticut](https://6ac.org/tag/connecticut/)
- [juvenile transfer hearings](https://6ac.org/tag/juvenile-transfer-hearings/)
- [Kansas](https://6ac.org/tag/kansas/)
- [New Hampshire](https://6ac.org/tag/new-hampshire/)
- [Actual Denial of COunsel](https://6ac.org/tag/actual-denial-of-counsel/)
- [Gideon v. Wainwright](https://6ac.org/tag/gideon-v-wainwright/)
- [US Department of Justice](https://6ac.org/tag/us-department-of-justice/)
- [Iowa](https://6ac.org/tag/iowa/)
- [Kern County CA](https://6ac.org/tag/kern-county-ca/)
- [Lake County CA](https://6ac.org/tag/lake-county-ca/)
- [San Benito County CA](https://6ac.org/tag/san-benito-county-ca/)
- [aditi goel](https://6ac.org/tag/aditi-goel/)

## Service Categories

- [Government Technical Assistance](https://6ac.org/service-categories/government-technical-assistance/)
- [Speaking Engagement](https://6ac.org/service-categories/speaking-engagement/)

## Team Categories

- [Board](https://6ac.org/team-categories/board/)
- [Staff](https://6ac.org/team-categories/staff/)

## Topics

- [When](https://6ac.org/topics/when/)
- [Who](https://6ac.org/topics/who/)
- [Where](https://6ac.org/topics/where/)
- [What](https://6ac.org/topics/what/)
- [Why](https://6ac.org/topics/why/)
- [How](https://6ac.org/topics/how/)

## ABC Categories

- [Why](https://6ac.org/abc-categories/why/)
- [Who](https://6ac.org/abc-categories/who/)
- [Where](https://6ac.org/abc-categories/where/)
- [When](https://6ac.org/abc-categories/when/)
- [What](https://6ac.org/abc-categories/what/)

## How Card Categories

- [How To Oversee](https://6ac.org/how-categories/how-to-oversee/)
- [How To Fund](https://6ac.org/how-categories/how-to-fund/)
- [How To Deliver](https://6ac.org/how-categories/how-to-deliver/)
- [How To Administer](https://6ac.org/how-categories/how-to-administer/)