Indiana v. Edwards (2008)

United States Supreme Court

554 U.S. 164

Nature of Case

Whether it is unconstitutional, according to 6th and 14th amendments, for a state to impose counsel on a defendant who is competent to stand trial and requests self-representation (i.e. can a state adopt a higher standard of competency for pro se defendants?).

Facts of Case

In July 1999, Amhad Edwards attempted to steal a pair of shoes from an Indiana department store, he shot at a security guard, and he wounded a bystander. He was charged with attempted murder, battery with a deadly weapon, criminal recklessness, and theft. He was diagnosed with schizophrenia, was found incompetent to stand trial, and was committed to a state hospital. When he was ultimately found competent to stand trial, he requested to represent himself due to differing opinions with his defense counsel about the defense he wished to pursue. The trial judge said he was competent to stand trial but not competent to defend himself. Counsel was imposed and the defendant was found guilty. Edwards appealed on the grounds that his Constitutional rights were violated. The appellate court agreed with Edwards and granted him a new trial. On appeal, the Indiana Supreme Court affirmed the appellate court decision. Indiana petitioned the United States Supreme Court to hear the case and the Court granted cert.

Issue

If a defendant is found competent to stand trial, is the trial court required, according to the Constitution, to allow the defendant to represent himself at trial?

Holding

In a 7 to 2 decision, the Court vacated the decision of the Indiana Supreme Court. In an opinion delivered by Justice Breyer, the Court found that “the United States Constitution does not forbid the State from insisting that respondent proceed to trial with counsel.” The opinion further stated, “the Constitution permits states to insist upon representation by counsel for those competent enough to stand trial under Dusky but who still suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves.”

The Court did not outline a specific standard regarding what was required to be found competent for self-representation. Indiana had requested a specific standard requiring the defendant to be coherent in his communication with the court or jury, but the Court declined to use that standard. The Court stated that “the trial judge will often prove best able to make more fine-tuned mental capacity decisions, tailored to the individualized circumstances of a particular defendant.” The Court also refused to vacate their decision in Faretta as requested by Indiana.

Rationale

The Court concluded that the right to self-representation is not absolute. They cited that a single competency standard would be problematic, because a mental illness is not a unitary construct, and the magnitude with which it impacts a defendant’s competence related abilities can change over time. They stated that allowing a defendant to represent himself, when he does not have the mental capacity to do so “undercuts the most basic Constitutional right to a fair trial. The government’s interest in ensuring integrity and efficiency of the trial at times outweighs the defendant’s interest in acting as his own lawyer.” They determined that prior cases, such as Dusky, Godinez, and Faretta did not answer the question concerning right to self-representation that was presented in this case. Their opinion was that the Dusky and Drope cases presumed the defendant would be represented by an attorney and the Faretta case did not consider mental competency for self-representation. In Godinez, the Court solely looked at the defendant’s competence to waive his right to counsel and not his competence to represent himself, because the defendant only wanted to change his plea to guilty, he did not want to go to trial.

Dissenting opinion

Justice Scalia, joined by Justice Thomas dissented on the grounds that the “Constitution does not permit a State to substitute its own perception of fairness for the defendant’s right to make his own case before the jury – a specific right long understood as essential to a fair trial.” The Justices were of the opinion that if the defendant was competent to stand trial and could waive his rights to counsel knowingly and voluntarily, then the defendant had “a constitutional right to conduct his own defense.”