In the early years immediately following the adoption of the Sixth Amendment, guaranteeing the right to counsel, courts interpreted that right to mean:

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In the early years following the adoption of the Sixth Amendment, courts interpreted the right to counsel as meaning defendants have the right to have counsel present at trial, but it was contingent upon their ability to afford one. The broader interpretation that all defendants must receive counsel at government expense, regardless of their ability to pay, was not established until later through landmark cases such as Gideon v. Wainwright in 1963.

In the Early Years Immediately Following the Adoption of the Sixth