Scott, an indigent, was charged with a crime punishable by as much as one year in jail. He was tried without counsel, convicted and fined $$50.$ On appeal, the Supreme Court in Scott v$.$ Illinois $(1979)$:

held that Scott's right to counsel had been violated.

overruled Argesinger v$.$ Hamlin $(1972).$

referred to Argesinger v$.$ Hamlin and held, that imprisonment as a penalty is different from fines, and that "actual" imprisonment, not potential imprisonment, is the line defining the constitutional right to appointment of counsel.

decided that indigent defendants must be granted counsel in all cases when they face potential imprisonment.