In accordance with the provisions of the federal and most state constitutions, a person accused of a crime has the right to be heard and to be assisted by counsel in his defense. However, not until 1932 was the right to counsel for indigent criminal defendants recognized by the Supreme Court of the United States, and the extent of this right has remained unclear for forty years.
Constitutional Law-The Indigent Misdemeanant's Right to Counsel,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol7/iss2/11