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self-representation

Indiana v. Edwards

Issues

If a state trial court finds a defendant competent to stand trial, is it entitled to find the defendant not competent to represent himself at trial?

Court below

 

In 1999, Ahmad Edwards stole a pair of shoes from an Indiana department store and then shot at the store security guard who chased after him, wounding the guard and a passer-by. The State of Indiana charged Edwards with theft, criminal recklessness, battery, and attempted murder. In 2004, an Indiana trial court declared Edwards competent to stand trial but later denied Edwards' request to serve as his own lawyer. The judge said that Edwards, a diagnosed schizophrenic, was not competent to represent himself. Edwards then went to trial with counsel, a jury found him guilty, and he was sentenced to thirty years in prison. Edwards appealed, arguing that the court deprived him of his Sixth Amendment right to represent himself at trial. The Indiana Court of Appeals agreed with Edwards and called for a new trial. The appeals court held that once the trial court had found Edwards competent to stand trial, under United States Supreme Court precedent, the court could not impose a higher competency standard to determine whether he could act as his own lawyer. The Indiana Supreme Court affirmed the appeals court's decision. The Supreme Court will consider whether states may impose greater competency standards on defendants who wish to represent themselves than on ordinary defendants.

Questions as Framed for the Court by the Parties

May states adopt a higher standard for measuring competency to represent oneself at trial than for measuring competency to stand trial?

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