In the Miranda vs. Arizona case, the U.S. Supreme Court held that a defendant cannot be "assured a fair trial unless counsel is provided for him," and therefore the state must provide a public defender to those who cannot afford to hire one for themselves.

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The Miranda vs. Arizona case established the requirement for police to inform suspects of their rights, including the right to an attorney, during custodial interrogations, but it did not specifically address the provision of public defenders. The right to counsel was established in Gideon v. Wainwright.

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