strongly worded dissenting opinion. The defendants appealed the Alabama Supreme Court's ruling to the U.S. Supreme Court. The Supreme Court reversed and remanded, holding that due process had been violated. Writing for himself and six other Justices, Justice Sutherland explained the Court's ruling as follows: In the light of the ... ignorance and illiteracy of the defendants, their youth, the circumstances of public hostility, the imprisonment and the close surveillance of the defendants by the military forces, the fact that their friends and families were all in other states and communication with them necessarily difficult, and above all that they stood in deadly peril of their lives—we think the failure of the trial court to give them reasonable time and opportunity to secure counsel was a clear denial of due process. But passing that, and assuming their inability, even if opportunity had been given, to employ counsel, ... under the circumstances just stated, the necessity of counsel was so vital and imperative that the failure of the trial court to make an effective appointment of counsel was likewise a denial of due process within the meaning of the Fourteenth Amendment. The Court's holding was quite limited. Justice Sutherland cautioned that Whether this would be so in other criminal prosecutions, or under other circumstances, we need not determine. All that it is necessary now to decide, as we do decide, is that in a capital case, where the defendant is unable to employ counsel, and is incapable adequately of making his own defense because of ignorance, feeble-mindedness, illiteracy, or the like, it is the duty of the court, whether requested or not, to assign counsel for him as a necessary requisite of due process of law; and that duty is not discharged by an assignment at such a time or under such circumstances as to preclude the giving of effective aid in the preparation and trial of the case. ... In a case such as this, whatever may be the rule in other cases, the right to have counsel appointed, when necessary, is a logical corollary from the constitutional right to be heard by counsel. Subsequent jurisprudence Whether Powell v. Alabama applied to non-capital cases sparked heated debate. Betts v. Brady initially decided that, unless there were special circumstances such as illiteracy or a complicated trial, there was no need for a court-appointed attorney. That decision was ultimately overturned in Gideon