holding the right to assistance of counsel as announced in Gideon v. Wainwright, 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799, to be retroactive

giving retroactivity to Gideon v. Wainwright, 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799

In Doughty v. Maxwell, 1964, 376 U.S. 202, 84 S.Ct. 702, 11 L.Ed.2d 650, in a short per curiam opinion the Supreme Court reversed a state court conviction where the accused had failed to request counsel when pleading guilty; Doughty was convicted two years before Gideon's 1961 conviction.

In Doughty v. Maxwell, 376 U.S. 202, 84 S.Ct. 702, 11 L.Ed.2d 650 (1964), the Supreme Court in a per curiam decision reversed an Ohio Supreme Court decision denying petitioner relief where he was convicted on a guilty plea and did not make an affirmative request for counsel.