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Indiana v. Edwards

Supreme Court of the United States · 2008 · Criminal Procedure

Criminal ProcedureSixth AmendmentSelf-representationCompetency to stand trialMental illnessFarettaGodinezDusky

Facts

Edwards was charged after attempting to steal shoes, drawing a gun, firing at a store security officer, and wounding a bystander. Over several years, state courts held multiple competency hearings, at times finding him incompetent to stand trial and recommitting him, while psychiatric evidence showed schizophrenia, delusions, and serious thinking difficulties. After later being found competent to stand trial, Edwards twice asked to represent himself. At the retrial, the trial judge denied the request, concluding that although Edwards was competent to stand trial, he was not competent to defend himself, and Edwards was then convicted with appointed counsel representing him.

Issue

Whether the Constitution forbids a State from insisting that a criminal defendant proceed to trial with counsel when the defendant is competent to stand trial under Dusky if represented by counsel, but is not mentally competent to conduct the trial himself.

Rule

The Constitution permits a State to insist upon representation by counsel for a defendant who is competent enough to stand trial under Dusky, yet who still suffers from severe mental illness to the point where he is not competent to conduct trial proceedings by himself. The Court did not adopt Indiana's proposed federal constitutional standard focused on inability to communicate coherently with the court or jury.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Cleveland, Omar Silva is charged with armed robbery. Two psychiatrists testify that he understands the charges and can rationally assist appointed counsel, but because of severe schizoaffective disorder he cannot organize a defense, make coherent motions, or question witnesses without losing track of the proceedings. Omar insists on representing himself at trial.

If the trial judge requires Omar to proceed with counsel, is that constitutionally permissible?

Explanation. The Constitution permits a State to insist on counsel for the narrow class of defendants who satisfy the competency standard for standing trial with counsel, yet who still suffer from severe mental illness to the point that they are not competent to conduct trial proceedings by themselves. The majority emphasized that competency to stand trial assumes representation and does not necessarily equal competency to perform trial tasks unaided.