Coleman v. Alabama (1969)
- Docket
- 72
- Decided
- 1969-01-01
- Category
- General
Summary
Question: (1) Did denying Coleman and Stephens counsel during their preliminary hearing violate the Sixth Amendment? (2) Was the police line-up so unfairly suggestive that it violated due process under the Fourteenth Amendment? Conclusion: Yes, No. In a 5-3 decision, Justice William J. Brennan wrote the majority opinion vacating the convictions. The Supreme Court held that Reynolds' identification of Coleman and Stephens did not stem from a prejudicial police lineup. The Court also held that the preliminary hearing was a critical stage, so the defendants were constitutionally entitled to counsel. The Court remanded the case to determine whether denying counsel created an unfair prejudice against the defendants. Justice Hugo L. Black wrote a concurrence, expressing that the right to counsel is guaranteed by the Sixth and Fourteenth Amendments rather than on the basis of holding a fair trial. Justice William O. Douglas wrote a concurrence, also expressing that the right to counsel is guaranteed under the Sixth Amendment. Justice Byron R. White wrote a concurrence, stating that requiring counsel for preliminary hearings might induce courts to eliminate preliminary hearings all together. Justice John M. Harlan wrote a partial dissent, stating that the convictions should not be overturned unless Coleman and Stephens can show that they lost favorable testimony during the preliminary hearing that otherwise would be preserved. Chief Justice Warren E. Burger wrote a dissent, expressing that the Constitution does not guarantee assistance of counsel at a preliminary hearing. Justice Potter Stewart wrote a separate dissent, also stating that defendants are not entitled to counsel at a preliminary hearing. Justice Harry A. Blackmun did not participate.