Note 820 — AMENDMENT 14 (continued 4)

287 U.S. 45, 71 (1932).—The Court presently seems to be holding that in capital cases, notwithstanding the absence even of other circumstances prejudicial to the defendant, the right to counsel is unqualified. See the later cases discussed herein, especially Tomkins v. Missouri, 323 U.S. 485 (1945); Williams v. Kaiser, 323 U.S. 471 (1945); Hawk v. Olson, 326 U.S. 271 (1945); and the Court's summary of its rulings in Uveges v. Pennsylvania, 335 U.S. 437 (1948), supra, p. 1108.