United States v. Gouveia et al.

• Jurisdiction: United States

United States v. Gouveia et al.

467 U.S. 180 (1984)

Facts

In November 1978, an inmate at the Federal Correctional Institution in Lompoc, California, was found dead from forty-five stab wounds to the chest. Four indigent prisoners were placed in administrative detention during the investigation of their fellow inmate's death, and remained there for nineteen months before they were indicted and arraigned in federal District Court for murder, at which time counsel was appointed for them. While in detention, the prisoners were allowed regular visitation privileges, access to legal materials, exercise, and unmonitored phone calls. Before trial, the prisoners filed a motion to dismiss the case against them, claiming that their Sixth Amendment right to counsel was violated when they were placed in administrative detention without the benefit of counsel. The U.S. District Court for the Central District of California denied their motion, and they went to trial. The proceeding lasted for a week, ending in a mistrial. On retrial, the respondents were eventually convicted of first-degree murder and conspiracy to commit murder.

In August 1979, another inmate was stabbed to death at the same institution. This time, two other prisoners were suspected of the murder and placed in administrative detention, where they remained for eight months. In March 1980, the two inmates were indicted by a federal grand jury for murder, and in April 1980 both prisoners were appointed an attorney and released from detention. Before trial, both prisoners filed a motion to dismiss the indictments against them on the grounds that their confinement in detention without appointed counsel violated their due process right of the Fifth Amendment and their Sixth Amendment right to a speedy trial and the right to counsel. This time, the U.S. District Court for the Central District of California dismissed the two prisoners' lawsuits, but a panel of the U.S. Court of Appeals for the Ninth Circuit reversed. The Court of Appeals for the Ninth Circuit, en banc, joined the appeals of the six prisoners and reversed, holding that denying the prisoners counsel while they were held in administrative detention before the indictments were handed down violated their Sixth Amendment right to counsel and overturned all six murder convictions. The case was appealed to the U.S. Supreme Court, and it granted certiorari.

Issue

Whether the Sixth Amendment requires the appointment of counsel to indigent inmates during...