Right to Counsel

7 See generally Kamisar & Choper, The Right to Counsel in Minnesota: Some Field Findings and Legal-Policy Observations, 48 MiNm.L. REv. 1, 4-9 (1963).8 372 U.S. 335 (1963).9 372 U.S. 353 (1963).30 316 U.S. 455 (1942), which had held that the totality of the circumstances deter- mined whether a right to counsel existed at the trial level.Among the factors the Court considered important were the intellectual qualifications of the defendant and the complexity of the case.Id. at 472. 11 372 U.S. at 344.