Hugo Black,
Pennsylvania ex rel. Herman v. Claudy…
“ Moreover, the number and complexity of the charges against petitioner, as well as their seriousness create a strong conviction that no layman could have understood the accusations and that petitioner should, therefore, have been advised of his right to be represented by counsel. We cannot agree with the Pennsylvania Superior Court that the mere fact that petitioner had, without the benefit of counsel, pleaded guilty to an offense 2 years before showed that he had the capacity to defend himself against the 30 charges here. ”
