Indiana v. Edwards

PETITIONER: Indiana
RESPONDENT: Ahmad Edwards
LOCATION: Marion County Superior Court: Criminal Division

DOCKET NO.: 07-208
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: Supreme Court of Indiana

CITATION: 554 US 164 (2008)
GRANTED: Dec 07, 2007
ARGUED: Mar 26, 2008
DECIDED: Jun 19, 2008

ADVOCATES:
Michael R. Dreeben - on behalf of the United States, as amicus curiae, supporting the Petitioner
Mark T. Stancil - on behalf of the Respondent
Thomas M. Fisher - on behalf of the Petitioner

Facts of the case

Ahmad Edwards was arrested in Indiana after stealing a pair of shoes and shooting an FBI agent, a store security guard, and a bystander. Edwards was initially found mentally incompetent but, after five years of psychiatric evaluation, was put on trial for attempted murder. After his first trial resulted in a hung jury, Edwards asked to represent himself at his retrial. This request was initially granted by the trial court but was overturned when the court found that, although Edwards was competent to stand trial, he was unable to conduct a coherent defense. This ruling was supported by Edwards' filing of rambling and irrelevant documents during the proceedings.

After his conviction on all counts, Edwards appealed to the Supreme Court of Indiana claiming that his Sixth Amendment right to self-representation had been abrogated by the trial court. The Indiana high court noted that two Supreme Court decisions, Godinez v. Moran 509 U.S. 389 (1993), which held that a defendant is competent to defend himself if he is competent to stand trial, and Faretta v. California 422 U.S. 806 (1975), which held that a defendant need only be "literate, competent, and understanding" to represent himself, argued in favor of Edwards' right to self-representation while another, Martinez v. Court of Appeal of California 528 U.S. 152 (2000), holding that the modern availability of lawyers undercuts the need for self-representation, argued against it. The Indiana Supreme Court eventually held that Godinez and Faretta required it to overturn the trial court's decision.

Question

Does the Court's prior ruling that a criminal defendant need only be "literate, competent, and understanding" to represent himself at trial set an appropriate standard for defining that defendant's mental competence to invoke his Sixth Amendment right to self-representation when he is otherwise unable to conduct a coherent defense?

Media for Indiana v. Edwards

Audio Transcription for Oral Argument - March 26, 2008 in Indiana v. Edwards

Audio Transcription for Opinion Announcement - June 19, 2008 in Indiana v. Edwards

Stephen G. Breyer:

The second case -- the third case is not so complicated.

Here, a state court, that's Indiana v. Edwards, a state court found the criminal defendant in this case competent to stand trial if he was represented by counsel, mentally competent.

But he is not mentally competent to conduct the trial proceedings himself without a counsel, that’s what the trial judge said.

The Indiana State Supreme Court concluded that this Court's precedents don't allow that, that they require the trial court to allow the defendant, nonetheless, to conduct the trial proceedings himself.

So, we have to decide whether that’s so.

Does the constitution forbid a State from insisting that the defendant like this who the State thinks is not competent mentally to conduct the proceedings himself?

Does it forbid a State for insisting that such a defendant proceed to trial with a lawyer, not without one?

Thereby, denying the defendant the right to represent himself under the Sixth Amendment which we have explained the case called Faretta.

We conclude that the State may insist a defendant be represented by counsel where that defendant is not mentally competent to conduct the trial proceedings himself.

First, in our view, the relevant precedents do not decide the question presented here.

They assume the constitutional right of self representation.

They assume that that right set forth in Faretta can be limited in various ways.

Second, the mental competency that a defendant needs to represent himself during the trial, can differ dramatically from the mental competency he needs to proceed to trial with a lawyer, and third, to permit a defendant to represent himself a trial when he is mentally incompetent to do so.

In our opinion, does not at all affirmed that defendant's dignity but rather it threatens to undermine the most basic of the constitution's criminal law objectives, namely, providing a fair trial.

We add that the trial judge is in the best position to determine the presence or degree of the defendant’s mental competence.

And we conclude that the State may insist that a criminal defendant be represented by counsel at the trial when that defendant who is mentally competent to stand trial with a lawyer, is not mentally competent to stand trial without one.

And these points which are a little abstract, are very concretely and very well-represented by the facts of this case right before us which are explained in the opinion.

So, we vacate the decision of the Indiana Supreme Court and remand for further proceedings.

Justice Scalia has filed a dissenting opinion which Justice Thomas has joined.