Alabama V. Shelton

535 U.S. 654 (2002)

Lereed Shelton represented himself at trial for third degree assault, a misdemeanor. At no time did the trial court offer him assistance of counsel, though the judge repeatedly warned Mr. Shelton about the problems self-representation entailed. He was convicted and sentenced to 30 days in jail. The court immediately suspended Mr. Sheltoǹs jail sentence and placed him on two years̀ probation.

Constitutional Issue
The question presented to the Court was whether an indigent defendant charged with a misdemeanor punishable by imprisonment but where the jail sentence was suspended is entitled to the assistance of counsel under the Sixth Amendment. Drawing on the rationale of Argersinger, the Court held that a suspended sentence that may end up in the actual deprivation of a persoǹs liberty may not be imposed unless the defendant was accorded the guiding hand of counsel in the prosecution for the crime charged.

Upcoming Training
For more information, contact:
LPDB Training Division at

Friday, May 31, 2019
1144 N Causeway Blvd.
Benedict’s Plantation
526 Pine Street
Mandeville, Louisiana

6.25 hours CLE, including Ethics & Professionalism

Registration Form

For more information contact:

Chris Aberle, Director
Louisiana Appellate Project
P. O. Box 8583
Mandeville, LA 70470-8583
(985) 871-4084

Eyewitness Identification Training
Friday, May 17, 2019
10:00 a.m. – 12:15 p.m.
The Bienville Parish Courthouse
100 Courthouse Drive
Arcadia, LA 71001

The training will focus on the science of memory and eyewitness
identifications, and Act 466. Additionally, we will discuss how to
reframe and challenge Manson v. Braithwaite 432 U.S. 98 (1977) and
State v. Young, 35 So. 3d 1042 (La. 2010) given the scientific
developments and case law from other jurisdictions. A list of helpful
cases and model motions will be available at the training. We are seeking
CLE credit for the training and have capacity for approximately 55

Click HERE for more information and the registration form.

Upcoming NAPD Trainings

NAPD offers several trainings throughout the year. Please visit NAPD's website to see more information about all of their upcoming trainings and events.