Following the Court’s decision in Gideon v. Wainwright, popular opinion allowed indignant criminals seeking a re-trial to receive harsher sentences. This examination argues that such a result is unconstitutional.
74 Yale Law Journal 606-639 (1965)
Van Alstyne, William W., "In Gideon’s Wake: Harsher Penalties and the “Successful” Criminal Appellant" (1965). Faculty Publications. 781.