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See also Sixth Amendment. A criminal’s Sixth Amendment right to confront witnesses against her. The Sixth Amendment is a part of what the Bill of Rights. In Gideon v. Wainwright the Supreme Court held that the Sixth Amendment's right to the assistance of counsel is obligatory upon the States. It did so on the ground that 'a provision of the Bill of Rights which is `fundamental and essential to a fair trial' is made obligatory upon the States by the Fourteenth Amendment.' 372 U.S., at 342. In Malloy v. Hogan, 378 U.S. 1, in holding that the Fifth Amendment's guarantee against self-incrimination was made applicable to the States by the Fourteenth, the Court reiterated the holding of Gideon that the Sixth Amendment's right-to-counsel guarantee is '`a fundamental right, essential to a fair trial,'' and 'thus was made obligatory on the States by the Fourteenth Amendment.' 378 U.S., at 6. See also Murphy v. Waterfront Comm'n, 378 U.S. 52.


The Court then held in Pointer v. Texas 380 U.S. 400 (1965) that the Sixth Amendment's right of an accused to confront the witnesses against him is likewise a fundamental right and is made obligatory ...

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