Hudson v. North Carolina, 363 U.S. 697 (1960)

Hudson v. North Carolina

No. 466

Argued May 16, 1960
Decided June 20, 1960
363 U.S. 697

CERTIORARI TO THE SUPREME COURT OF NORTH CAROLINA

Syllabus

Petitioner and two others were tried before a jury in a North Carolina state court on an indictment jointly charging them with robbery. Petitioner, who was 18 years old, asked the judge to appoint a lawyer to help him in his defense, stating that he was without funds to employ counsel and was incapable of defending himself; but this request was denied. Counsel for one of petitioner’s codefendants volunteered to help petitioner and the third defendant, but, in the midst of the trial and in the presence of the jury, his client pleaded guilty to petit larceny, that plea was accepted, and the lawyer withdrew from the proceedings. No steps were taken to protect petitioner from the potential prejudice resulting from the guilty plea of his codefendant in the presence of the jury, and petitioner and his other codefendant were convicted of larceny from the person, a felony under North Carolina law.

Held: the prejudicial position in which petitioner found himself when his codefendant pleaded guilty before the jury raised problems requiring professional knowledge and experience beyond a layman’s ken, and petitioner’s conviction in these circumstances without the benefit of counsel deprived him of the due process of law guaranteed by the Fourteenth Amendment. Pp. 697-704.

Reversed.