Which of the following cases has nothing to do with the right to counsel?

Name: Which of the following cases has nothing to do with the right to counsel?
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Question

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Payne v. Tennessee dealt with the admissibility of victim impact statements during the sentencing phase of a trial, not the right to counsel. Gideon v. Wainwright, Powell v. Alabama, and Johnson v. Zerbst all significantly involve the right to counsel in various contexts.

Which of the Following Cases Has Nothing to Do with the Right