Indiana v. Edwards

554 U.S. 164 (2008)

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Nature of the Case

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Facts

Edwards (D) tried to steal a pair of shoes, and after he was discovered, he drew a gun, fired at a store security officer, and wounded a bystander. He was caught and then charged with attempted murder, battery with a deadly weapon, criminal recklessness, and theft. His mental condition became the subject of three competency proceedings and two self-representation requests, mostly before the same trial judge. Court-appointed counsel asked for a psychiatric evaluation. The court found Edwards incompetent to stand trial and committed him to Logansport State Hospital for evaluation and treatment. Seven months later, doctors found that D condition had improved to the point where he could stand trial. Several months later, however, but still before trial, D's counsel asked for another psychiatric evaluation. In March 2002, the judge held a competency hearing, considered additional psychiatric evidence, and (in April) found that D, while 'suffer[ing] from mental illness,' was 'competent to assist his attorneys in his defense and stand trial for the charged crimes.' Seven months later but still before trial, D's counsel sought yet another psychiatric evaluation of his client. A testifying psychiatrist reported that D could understand the charges against him, but he was 'unable to cooperate with his attorney in his defense because of his schizophrenic illness'; 'his delusions and his marked difficulties in thinking make it impossible for him to cooperate with his attorney.' The court concluded that D was not then competent to stand trial and ordered his recommitment to the state hospital. About eight months after his commitment, the hospital reported that D's condition had again improved to the point that he had again become competent to stand trial. Just before trial, D asked to represent himself. He also asked for a continuance, which, he said, he needed in order to proceed pro se. The court refused the continuance. D then proceeded to trial represented by counsel. The jury convicted him of criminal recklessness and theft but failed to reach a verdict on the charges of attempted murder and battery. The State decided to retry D on the attempted murder and battery charges. Just before the retrial, D again asked the court to permit him to represent himself. Referring to the lengthy record of psychiatric reports, the trial court noted that D still suffered from schizophrenia and concluded that 'with these findings, he's competent to stand trial, but I'm not going to find he's competent to defend himself.' D was represented by appointed counsel at his retrial. The jury convicted D on both of the remaining counts. On appeal, it was argued that the trial court's refusal to permit him to represent himself at his retrial deprived him of his constitutional right of self-representation. The court agreed and ordered a new trial. The matter then went to the Indiana Supreme Court. That court found that 'the record, in this case, presents a substantial basis to agree with the trial court,' but it nonetheless affirmed the intermediate appellate court on the belief that Faretta and Godinez required the State to allow D to represent himself. Indiana (P) appealed.