Chandler v. Fretag

In Chandler v. Fretag (1954) 348 U.S. 3, the defendant was charged in Tennessee with "breaking and entering a business house and stealing therefrom sundry items of the aggregate value of $ 3." ( Id. at p. 4.) He had been arrested on March 10, 1949, and his trial was set for May 17 of that year. On the day set for trial he "appeared in court intending to plead guilty to the indictment." (Ibid.) On that day, the trial judge informed him for the first time that he was also accused of being a habitual criminal. If the habitual criminal accusation were found true, the defendant faced a "mandatory life sentence of life imprisonment with no possibility of parole." ( Id. at p. 5.) The defendant "promptly asked for a continuance to enable him to obtain counsel on the habitual criminal accusation." (Ibid.) His request was denied. He entered a plea of guilty to the housebreaking and larceny charge, and received a three-year sentence for that crime. A jury found him to be a habitual criminal, and he was sentenced to life imprisonment. The U.S. Supreme Court reversed the judgment. The court stated: ... "a defendant must be given a reasonable opportunity to employ and consult with counsel; otherwise, the right to be heard by counsel would be of little worth. By denying petitioner any opportunity whatever to obtain counsel on the habitual criminal accusation, the trial court deprived him of due process of law as guaranteed by the Fourteenth Amendment." ( Id. at p. 10.)