Hamilton v. Alabama

holding that an arraignment was a critical stage of the proceedings because available defenses may be irretriev- ably lost | concluding that an arraignment was a critical stage because defenses not raised at that stage were waived | holding that arraignment is critical stage where right to counsel cannot be infringed | emphasizing that the defendant entered a plea and was required to raise or waive certain defenses | holding that because a defendant in Alabama could only raise certain defenses at arraignment, or else they are “irretrievably lost,” the arraignment necessarily was a critical stage in a criminal proceeding in that state | holding that because a defendant in Alabama could only raise certain defenses at arraignment, or else they are “irretrievably lost,” the arraignment necessarily was a critical stage in a criminal proceeding in that state | holding that an arraignment constitutes a critical stage of trial | holding that an arraignment constitutes a critical stage of trial | holding prejudice is presumed when a defendant is arraigned in a capital case without the benefit of counsel and pleads guilty | stating that denial of counsel at arraignment required reversal of conviction even though no prejudice was shown | holding that an arraignment constitutes a critical stage of trial | stating that, under federal law, "arraignment is a sine qua non to the trial itself" | holding prejudice is presumed when a defendant is arraigned in a capital case without the benefit of counsel and pleads guilty | holding that arraignment is a critical stage and that a critical stage 1 The Cronic decision cited decades of decisions that led it to this conclusion, including Geders v. United States, 425 U.S. 80 (1976); Herring v. New York, 422 U.S. 853 (1975 | explaining that a critical stage of a criminal proceeding is one where certain rights and available defenses will be “irretrievably lost” if not asserted at that time | reversing State's denial of postconviction relief for petitioner who was not represented by counsel at arraignment on capital charge | reversing State’s denial of postconviction relief for petitioner who was not represented by counsel at arraignment on capital charge | finding that in Alabama arraignment is a critical stage in a criminal proceeding because it affects the outcome of trial and, as a result of failure to make certain pleas, available defenses may be “irretrievably lost” | finding that arraignment under Alabama law is a critical stage in the criminal proceeding because the defense of insanity must be pleaded or the opportunity is forever lost and not reviewable on appeal | presuming prejudice where defendant was completely without counsel when he pleaded guilty to a capital charge and irrevocably waived other pleas | presuming prejudice where defendant was completely without counsel when he pleaded guilty to a capital charge and irrevocably waived other pleas | rejecting harmless-error analysis where "the degree of prejudice can never be known" | rejecting harmless-error analysis where “the degree of prejudice can never be known” | finding a Sixth Amendment violation where the absence of counsel “may affect the whole trial” | reversing conviction of a defendant arraigned without counsel, because “[o]nly the presence of counsel could have enabled this accused to know all the defenses available to him.... ” | holding right to counsel at police line-up | explaining several defenses are “irretrievably lost” if not asserted at arraignment | “Only the presence of counsel could have enabled this accused to know all the defenses available to him and to plead intelligently” | “Only the presence of counsel could have enabled this accused to know all the defenses available to him and to plead intelligently” | Alabama arraignment proceedings held critical because accused required to plead all available defenses or waive them thus absence of counsel denied accused substantive rights | absence of counsel on entry of