On June 12, 1972, The United States Supreme Court held in Argersinger v. Hamlin, ... that absent a knowing and intelligent waiver, no person may be imprisoned for any offense, whether classified as petty, misdemeanor, or felony, unless he was represented by counsel at his trial. Although, all of the ramifications of this decision have not yet been felt, American Bar Association president, Robert W. Meserve has estimated that the decision will require the legal profession to provide representation in some additional two to four million cases per year for indigent defendants alone.
Case Comment, Argersinger v. Hamlin - Right to Counsel Expanded to Include Offenses Which May Result in Imprisonment, 22 Clev. St. L. Rev. 367 (1973)