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Law School Case Briefs
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Nichols v. United States
Supreme Court of the United States (1994) | 128 L. Ed. 2d 745; 114 S. Ct. 1921; 511 U.S. 738; 1994 U.S. LEXIS 4277; 62 U.S.L.W. 4421
TL;DR: The Court held that an uncounseled misdemeanor conviction, valid because no jail time was imposed, may be used to enhance a prison sentence for a subsequent offense. This overruled prior precedent and clarified the scope of the Sixth Amendment right to counsel in sentencing proceedings.
Legal Significance: This case resolved a significant circuit split by explicitly overruling *Baldasar v. Illinois*. It established that an uncounseled misdemeanor conviction, valid under *Scott v. Illinois* because no imprisonment was imposed, can be used to enhance punishment for a subsequent offense without violating the Sixth Amendment.