Every defendant facing criminal prosecution that may result in imprisonment is guaranteed the right to counsel. The Supreme Court has required appointed counsel for indigents in widening classes of cases and at different stages of prosecution. This trend has increased the burden on public revenues, and many states, in an effort to recover some of the costs, have enacted recoupment statutes. Several state courts have expressed unfavorable opinions as to the constitutionality of these statutes. The first Supreme Court decision to focus on a state recoupment statute struck it down as violative of the equal protection clause.
Constitutional Law-Equal Protection-Reimbursement of Appointed Counsel Fees as a Condition of Probation Held Not Violative of the Equal Protection Clause,
U. Rich. L. Rev.
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