Gideon v. Wainwright (372 U.S. 335 (1963) "required states and localities ... to furnish counsel in the case of indigent persons charged with a felony"; Miranda v. Arizona [384 U.S. 436 (1966)] held that "police interrogation of any suspect in custody, without his consent, unless a defense attorney is present, is prohibited by the self-incrimination provision of the Fifth Amendment." In each of these decisions, according to Blumberg, "the Supreme Court reiterated the traditional legal conception of a defense lawyer based on the ideological perception of a criminal case as an adversary, combative proceeding, in which counsel for the defense assiduously musters all the admittedly limited resources at his command to defend the accused." Blumberg’s analysis, however, showed that the "Supreme Court’s conception of the role of counsel in criminal case [does not] square with social reality." [Abraham S. Blumberg, "The Practice of Law as Confidence Game: Organizational Cooptation of a Profession," 1 L. & Soc. Rev.  15 (1967)]