Supreme Court: Not All Defendants Can Represent Themselves
If you’re mentally competent to stand trial, are you necessarily mentally competent to act as your own attorney?
In 1999, Ahmed Edwards fired several shots while attempting to evade capture after stealing shoes from an Indianapolis department store. Though possibly schizophrenic – various psychiatrists disagreed on his diagnosis – he was brought to trial on charges including battery with a deadly weapon and attempted murder. He represented himself and was convicted of criminal recklessness and theft, but the jury was deadlocked on the more serious charges.
In a second trial, the judge ruled that Edwards was not competent to defend himself and attorneys were assigned. Edwards was convicted of the battery and attempted murder charges.
He appealed on the grounds that the trial judge had violated his right to represent himself. The Indiana Supreme Court agreed, and overturned the convictions.
Last Thursday, the U.S. Supreme Court reversed the Indiana court’s ruling, ruling 7-2 that the state had a right to require a higher level of competency for a defendant who wants to defend himself.
And there’s a common sense aspect to this as well: If a defendant were convicted after being represented by an attorney with an apparent mental illness, wouldn’t he have a valid case for appealing that conviction on the grounds of inadequate counsel?
June 24th, 2008 at 1:03 pm
I thought I read an article on the Stella Awards or something similar where a criminal represented himself in court, was convicted, but appealed on the grounds that his attorney (himself) didn’t represent him well. I don’t remember how the appeal worked out, but I somehow doubt that it was in his favor.
June 24th, 2008 at 1:13 pm
Well you know, the old expression is true: a boderline schizophrenic who defends himself has a borderline schizophrenia for an attorney.
June 24th, 2008 at 1:31 pm
“[A] defendant who exercises his right to represent himself cannot later complain that the quality of his defense amounted to a denial of the effective assistance of counsel.” (People v. Garcia (2000) 78 Cal.App.4th 1422, 1430.)
June 24th, 2008 at 1:41 pm
I wonder whether the appeals court would have ruled differently in a case where the judge knew the defendant had a mental impairment and let him defend himself anyway.
And regarding the Garcia case, do you happen to know whether it was ever appealed to SCOTUS?
June 24th, 2008 at 5:54 pm
I doubt the Garcia court could have ruled any differently under the law at the time, since the high court’s 1993 decision in Godinez v Moran strongly implied (if it did not expressly rule) that competency to stand trial and competency to waive counsel were the same thing in all circumstances — and the law is not so much of an ass that it would reverse for allowing a defendant to waive a right that the judge could not preclude him from waiving.
As an aside, I think Breyer’s purported distinction of the Godinez decision doesn’t hold water and will do nothing more than generate more litigation on a question that most of us thought was settled.
As best I can tell, there was no petition for certiorari in Garcia. Nothing shows in the case history on Westlaw and the appellate court docket number gets no hits on the SCOTUS website. Denial of discretionary review in the California Supreme Court appears to have been the end of the road for that one.