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Indiana v. Edwards | 554 U.S. 164 (2008)
In Faretta versus California, the United States Supreme Court held that a criminal defendant has a right to waive his Sixth Amendment right to counsel and defend himself at trial. But what if the defendant is so mentally ill that, despite being mentally competent to stand trial, he lacks the capacity to represent himself at trial? Does Faretta still require a trial court to allow such a defendant to represent himself? The Court addressed this issue in Indiana versus Edwards.
Ahmad Edwards attempted to shoplift shoes. After the store’s security officer confronted him, Edwards fired a pistol, wounding a bystander. Edwards was charged with theft, attempted murder, recklessness, and battery. Because he was indigent, the trial court appointed Edwards an attorney. After a psychiatric evaluation concluded that Edwards was schizophrenic and delusional, the court found that Edwards was incompetent to stand trial under the standard set forth in Dusky versus United States. The court then committed Edwards to a state psychiatric hospital for treatment. After a lengthy period of treatment, the court found that Edwards had regained his competency.
At his jury trial, Edwards asked to represent himself, but the court denied the request. Edwards’s court-appointed counsel represented him at the trial. The jury convicted Edwards of criminal recklessness and theft but couldn’t reach a verdict on the attempted murder and battery charges. At his retrial on the latter two charges, Edwards again asked to represent himself. Citing the psychiatric reports, the court found that Edwards suffered from severe schizophrenia and concluded that, although Edwards was competent to stand trial under Dusky, he wasn’t competent to defend himself at trial pursuant to Faretta. The court thus denied Edwards’ request. Edwards was represented by appointed counsel at his retrial. The second jury convicted Edwards of attempted murder and battery.
On appeal, the Indiana Court of Appeals reversed Edwards’s convictions, concluding that the trial court had violated Faretta by not allowing Edwards to represent himself. On further appeal to the Indiana Supreme Court, that court affirmed the Court of Appeals.
The State of Indiana successfully petitioned the United States Supreme Court to review Edwards’s case.
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