14th Amendment prohibits convictions and incarceration of one whose trial is offensive to the
common and fundamental ideas of fairness and right.(DP violation) Betts Rule: – right to counsel only in “special circumstances” under which only without a counsel there is no possibility of acquittal ***highly unstable (here no special circumstances found because D was intelligent and had been thru the court system before) Dissent (Black): 14th Am. incorporates 6th Am. It is not fair to subject a man to an increased chance of conviction simply because he is poor.