Abstract

The Supreme Court decisions of Powell v. Alabama,' Gideon v. Wainwright2 and Argersinger v. Hamlin3 have had tremendous impact on the operation of the state criminal courts. These decisions have forced jurisdictions to broaden the right to counsel during adjudication and to establish some systematic organization for providing representation for indigent defendants. Other Supreme Court rulings have extended the right to counsel for indigents in arraignment4 and sentencing hearings.5 A number of studies have explored the quality of defense provided by various types of indigent defense systems. The majority of this research has compared the consequences of defense by a public defender with those of defense provided by privately retained counsel. Often research has concluded that private counsel obtain superior outcomes for the defendant.6 Joyce Sterling notes, however,

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