Indiana v. Edwards, 554 U.S. 164 (2008), was a United States Supreme Court case in which the Court held that the standard for competency to stand trial was not linked to the standard for competency to represent oneself.
Background
Prior jurisprudence
The Court had recognized these two rights on competency for some time. In Dusky v. United States, , and in Drope v. Missouri, , the Court established the standard for competency to stand trial—the defendant must have a "rational and factual understanding" of the nature of the proceedings, and must be able to rationally assist his lawyer in defending him. In Faretta v. California, , the Court held that a criminal defendant cannot be forced to have a lawyer if he does not wish it, but that before the defendant relinquishes his right to counsel the trial judge must ensure that the defendant understands the "dangers and disadvantages" of representing himself. With the decision in Godinez v. Moran, , the Court held that a defendant may plead guilty (and thereby waive both his right to counsel and his right to represent himself) if he is competent to stand trial. Until Edwards, however, it remained an open question whether a criminal defendant could be simultaneously competent to stand trial and yet not competent to represent himself. The Court answered that question in the affirmative. The logic is that representing oneself at trial is more complicated than deciding what to plead.
Edwards' trial
Ahmad Edwards, who suffers from schizophrenia, tried to steal a pair of shoes from a department store in Indiana. Store detectives caught him in the act, and he drew a gun, fired at a store security officer, and wounded an innocent bystander. He was charged with attempted murder, battery with a deadly weapon, criminal recklessness, and theft.
In 2000, he was deemed not competent to stand trial, and ordered to the state hospital for treatment. After seven months of treatment, he was restored to competency. Yet in 2002, his lawyers asked for another competency evaluation. That second competency evaluation resulted in a determination that Edwards was indeed competent to stand trial, although he still suffered from a mental illness. As trial preparations proceeded, his lawyers asked for a third competency evaluation, and in 2003 Edwards was again found not competent to stand trial and again committed to the state hospital. Eight months later, Edwards was again restored to competence, and trial preparations began again.
In June 2005, as trial began, Edwards asked to represent himself and asked for a continuance in the trial. The judge denied the request for a continuance, and Edwards therefore proceeded to trial with counsel. He was convicted of criminal recklessness and theft, but the jury could not reach a verdict as to the attempted murder and battery charges. Before the second trial on the attempted murder and battery charges, Edwards again asked to represent himself. The judge denied that request, pointing to the lengthy record of Edwards's mental illness. Edwards proceeded to trial with appointed counsel, and was convicted of the attempted murder and battery charges.
Appeals
Edwards appealed to the Indiana Court of Appeals, arguing that his right to represent himself at trial was violated. The court agreed with Edwards and ordered a new trial. The State then appealed to the Indiana Supreme Court, which also agreed with Edwards. It reasoned that Faretta and Moran required the state to allow Edwards to represent himself at trial. The State of Indiana asked the U.S. Supreme Court to review the decision, and it agreed to do so.