Alabama v. Shelton
United States Supreme Court
535 U.S. 654 (2002)
Relevant factsFree
Shelton (defendant) represented himself, without appointed counsel, in a jury trial for third-degree assault and was convicted and sentenced to 30 days, with the sentence immediately suspended in favor of probation conditioned on paying court costs. He argued his Sixth Amendment right to counsel was violated because the sentence carried the possibility of future imprisonment if his probation was later revoked, and the Alabama Supreme Court agreed, invalidating the prison-time portion of the sentence while affirming the conviction.
IssueFree
Whether a defendant who receives a suspended sentence carrying the possibility of future imprisonment is entitled to appointed counsel under the Sixth Amendment.