Background Indiana v. Edwards

1 background

1.1 prior jurisprudence
1.2 edwards trial
1.3 appeals

background
prior jurisprudence

the court had recognized these 2 rights on competency time. in dusky v. united states, 362 u.s. 402 (1960), , in drope v. missouri, 420 u.s. 162 (1975), court established standard competency stand trial—the defendant must have rational , factual understanding of nature of proceedings, , must able rationally assist lawyer in defending him. in faretta v. california, 422 u.s. 806 (1975), court held criminal defendant cannot forced have lawyer if not wish it, before defendant relinquishes right counsel trial judge must ensure defendant understands dangers , disadvantages of representing himself. decision in godinez v. moran, 509 u.s. 389 (1993), court held defendant may plead guilty (and thereby waive both right counsel , right represent himself) if competent stand trial. until edwards, however, remained open question whether criminal defendant simultaneously competent stand trial , yet not competent represent himself. court answered question in affirmative. logic representing oneself @ trial more complicated deciding plead.

edwards trial

ahmad edwards, suffers schizophrenia, tried steal pair of shoes department store in indiana. store detectives caught him in act, , drew gun, fired @ store security officer, , wounded innocent bystander. charged attempted murder, battery deadly weapon, criminal recklessness, , theft.

in 2000, deemed not competent stand trial, , ordered state hospital treatment. after 7 months of treatment, restored competency. yet in 2002, lawyers asked competency evaluation. second competency evaluation resulted in determination edwards indeed competent stand trial, although still suffered mental illness. trial preparations proceeded, lawyers asked third competency evaluation, , in 2003 edwards again found not competent stand trial , again committed state hospital. 8 months later, edwards again restored competence, , trial preparations began again.

in june 2005, trial began, edwards asked represent himself , asked continuance in trial. judge denied request continuance, , edwards therefore proceeded trial counsel. convicted of criminal recklessness , theft, jury not reach verdict attempted murder , battery charges. before second trial on attempted murder , battery charges, edwards again asked represent himself. judge denied request, pointing lengthy record of edwards s mental illness. edwards proceeded trial appointed counsel, , convicted of attempted murder , battery charges.

appeals

edwards appealed indiana court of appeals, arguing right represent himself @ trial violated. court agreed edwards , ordered new trial. state appealed indiana supreme court, agreed edwards. reasoned faretta , moran required state allow edwards represent himself @ trial. state of indiana asked u.s. supreme court review decision, , agreed so.