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. Shelton's jail sentence and placed him on two years' 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 person's liberty may not be imposed unless the defendant was accorded the guiding hand of counsel in the prosecution for the crime charged.

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