Facts
Ahmed Edwards was arraigned in court for firing three shots and wounding a security officer and a bystander. The defendant was charged with attempted murder, battery with a deadly weapon in addition to theft and criminal recklessness (Beck, 2013). Edwards was suffering from mental illness which gave rose to competency hearings. The first two hearings dismissed his case pending medical attention for his schizophrenia, which made psychiatrist question his ability to cooperate with his attorneys (Beck, 2013). Edwards requested for self-representation which was turned down by the courts on the grounds that Edwards was not competent enough to represent himself even though he was competent enough to stand trial (Beck, 2013). However, after conviction on two of the offences, Edwards appealed on the grounds that the court deprived him of his 6 th amendment right (Beck, 2013). The court of Appeal ruled in favor of Edwards while the Supreme Court agreed with the rulings of the Court of Appeals.
Procedural History
The Indiana State Court found that Edwards was mentally ill and therefore incompetent to stand trial (Beck, 2013). A second hearing in the same trial court was held based on the doctor’s opinion that the condition of the defendant had improved (Beck, 2013). However, the judge found that Edward was suffering from Schizophrenia which his attorney indicated would not affect Edwards’s ability to understand the facts of the case even though he was deemed unfit to stand trial (Beck, 2013). A third competency trial indicated that Edwards had recovered and was mentally fit enough to stand trial.
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Upon commencement of trial, Edwards requested to represent himself, a request that was turned down and Edwards convicted on criminal recklessness and theft even though it did not reach a verdict. The Second trial Edward’s request for self-representation was thwarted with the court noting that a diagnosis with schizophrenia delineated that Edward was not competent enough to stand trial (Beck, 2013). Edwards was convicted on the two counts even though he appealed siting deprivation of his 6 th amendment right to represent himself in the trial.
The Indiana Court of Appeal ordered a new trial on the two previously dismissed counts in addition to affirming that indeed the plaintiff was denied of his sixth amendment rights (Beck, 2013). The court held it that a criminal cannot be held to standards higher than those that are used to measure the competency of individuals to stand trial (Beck, 2013). The Court of Appeal held it that the trial court should have allowed Edwards to represent himself if that was his wish. The Indiana Supreme court held it that the prior ruling was correct (Beck, 2013). The Supreme Court ruled that the self-representation right deemed it fit to allow individuals fit to stand trial to represent themselves stating that the competency standards should be similar for standing trial and representing one-self during a trial.
Issue
In Edwards v. Indiana, despite the charges of crimes that the defendant is accused of having committed, the main issues of contention are the mental illness of the defendant in addition to the right for self-representation (Taranto et al., 2008). In the trial courts, the defendant is faced with the counts of charges against him and in addition to this his mental competence is put to question in three separate but concurrent hearings (Taranto et al., 2008). Furthermore, during the trial court hearings the issue of the right for self-representation arises where the court dismisses the issue.
Self-representation is a prevalent issue that arises in the Court of Appeal and subsequently in the Supreme Court where parties try to determine the standards to be applied to defendants who desire to represent themselves before a court of law (Taranto et al., 2008). Both the appellate court and the Supreme Court ruled that self-representation is a constitutional right for every defendant who has been deemed fit to stand trial.
Rules
The main rule in question is the Sixth Amendment right also referred to as the Faretta right as conferred in the Faretta v. California ruling (Taranto et al., 2008). However, the Supreme Court asserted that this rule does not consider the issue of mental competency of a defendant (Taranto et al., 2008). However, the court upheld that it is the right of a defendant to represent themselves as long as they are deemed fit to stand trial.
Additionally, in Dusky v. US, the court ruling set precedence for the proclamation that it is unfit to stand trial for an individual whose mental illness affects the ability to comprehend proceedings coupled with the ability to communicate with attorneys (Taranto et al., 2008). Furthermore, the court considered the law in Godinez v. Moran which addressed the ability of an individual to represent themselves given that the defendant sought to change to a guilty plea. The rule in Godinez determined that it was improper for a state to hinder a defendant to stand trial but not represent himself (Taranto et al., 2008). This rule could however not apply as the court ruled that it was unique to the circumstances of that case.
Application/ Analysis
With the facts of the case in light, the trial court ruled that Edwards could not represent himself before a court of law because his mental condition rendered him unfit. The court ruled in favor of this decision siting the fact that it had to ensure that the defendant received a fair hearing, given that it doubted his ability to communicate with his attorneys properly. Both the Court of Appeal and the Supreme Court recognized this as a reasonable fact for the trial courts to have in consideration. The 6 th amendment rule was additionally put into consideration given that it directly addressed the issue of the right to self-representation. However, the law does not cover the issue of competency of those who seek to represent themselves, and the court recognizes that this rule is limited (Taranto et al., 2008). Additionally, the Dusky ruling that issued guidelines on the mental competence of individuals who intend to stand trial was applied in the determination of the mental competency of the defendant. However, the rule does not issue provisions on the question of the mental competency of individual who intended to defend themselves (Taranto et al., 2008). It is therefore vital to acknowledge that given the sensitivity and diversity of mental illness and its effect, the Supreme Court determined that individuals who can stand trial should enjoy their Faretta rights.
Conclusion
The Supreme Court ruled that the sixth amendment right should be upheld and that an individual should be allowed to represent themselves as long as they have the mental competence to stand trial.
Opinion
The Supreme Court ruling on the right of a defendant to defend themselves in Indiana v. Edwards was correct. The ruling set precedence for the determination of the competency standards for individuals who seek to represent themselves, especially if mentally ill or if the court doubts their competency to defend themselves. The denial of the right to defend one-self deprives an individual of their sixth amendment rights. Additionally, it raises question on the fairness of the hearing given that the defendant has a right to the type of counsel and representation that they prefer.
References
Beck, A. (2013). Indiana v. Edwards: The prospect of a Heightened Competency Standard for Pro Se Defendants. Retrieved from http://lawreview.colorado.edu/wp-content/uploads/2013/11/11.-Beck_Final_s.pdf
Taranto, R. & Taranto, F. (2008). Brief for the American Psychiatric Association and American Academy of Psychiatry and the Law as Amici Curiae n Support of Neither Party. Retrieved from http://lawreview.colorado.edu/wp-content/uploads/2013/11/11.-Beck_Final_s.pdf
