The Gideon case, while a landmark, merely extended the reasoning of Powell v. Alabama, 287 U.S. 45 (1932), which had earlier ruled that the Constitution required legal counsel be appointed or otherwise provided for indigents accused in capital cases. Later cases such as In re Gault, 387 U.S. 1 (1967), Argersinger v. Hamlin, 407 U.S. 24 (1972), and Ake v. Oklahoma 470 U.S. 68 (1985) continued to extend the right to counsel and provide additional protections for indigents accused in criminal matters. Today, there is little question that indigents accused of criminal offenses that carry a possible punishment of confinement are entitled to an attorney and the other material requisites for mounting a defense to those charges. What is questionable, however, is whether the current system of delivering legal services in Texas to indigent defendants fosters - - or even permits-- effective representation. Fundamentally, the right to have legal counsel is hollow unless it is effective legal counsel.
https://static.prisonpolicy.org/scans/last.pdf