The case of Gideon v. Wainwright greatly expanded the traditional right to counsel but provided no guidelines or directions to the States to help them implement that right. The need for Supreme Court intervention has recently become particularly pressing. First, uncompensated appointments of attorneys hurt the involved defendants more than the attorneys. Both studies and current cases support the correlation between the amount of money expended for defense services and the resulting quality of representation. In fact, some attorneys admit to the existence of a dual standard for representing the indigent. Second, State legislatures are increasingly failing to allocate sufficient funds for indigent criminal defense services. In addition, attorneys continue to burden already-congested State court systems with escalating numbers of complaints and proceedings stemming from uncompensated appointments. A Supreme Court finding that an appointed attorney must be reasonably compensated for services would ease State court administrative burdens and prod recalcitrant State legislatures into more realistic and equitable allocations of funds for indigent defense services. The Court must recognize that an indigent criminal defendant cannot be adequately represented by an uncompensated attorney. A total of 190 notes are provided.