In Argersinger v. Hamlin, 407 U.S. 25 , 34 (1972), the Supreme Court rejected the argument that petty offenses and misdemeanors are too insignificant to warrant appointment of counsel for indigents. Distinguishing the right to appointed counsel from the right to trial by jury, the Court established a bright-line rule based on the punishment ultimately imposed, concluding "that incarceration was so severe a sanction that it should not be imposed unless an indigent defendant had been offered appointed counsel."