Abstract
The Sixth Amendment guarantees defendants in all criminal prosecutions the right to the assistance of counsel. The Sixth Amendment right to counsel not only enables the criminal justice system to operate, it also permits a criminal defendant to secure constitutional rights. This Note argues that litigation seeking a structural injunction-a detailed remedial order providing affirmative relief-to improve state systems for providing indigent defense services is necessary to promote compliance with the requirements of the Sixth Amendment right to counsel.
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