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The case of Gideon v. Wainwright can be used to illustrate this point. Cole summarizes the case:
Clarence Earl Gideon, a penniless Florida man, down on his luck and charged with breaking and entering a poolroom, claims that although he can't afford a layer, he has a constitutional right to have a lawyer appointed by the state to defend him. When the Florida trial court denies his request, [Gideon] represents himself, and is convicted. From prison, [Gideon] sends a hand-written note to the Supreme Court asking it to hear his case. ?Abe Fortas [is appointed] to argue Gideon's case, and then [the Court] rules that the Sixth Amendment guarantees indigent defendants the assistance of a lawyer in all serious criminal trials...
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