Douglas v. California

Meyers and Douglas (defendant), indigent co-defendants, were tried together and convicted of thirteen felonies while sharing one public defender, who unsuccessfully sought a continuance and separate counsel for each client, citing an unmanageable caseload and a conflict of interest. After both were convicted on all counts, they each sought appointed counsel for their appeal as of right; their requests were denied, and the court of appeals affirmed their convictions without providing counsel. The state supreme court denied discretionary review, and the U.S. Supreme Court granted certiorari.