The United States Supreme Court has ruled that the Sixth Amendment right of criminal defendants to represent themselves can be denied to those whose mental illness makes them unable to competently do so.
The Court’s 7-2 decision in Indiana v. Edwards concluded that its 1975 decision in Faretta v. California leaves states with the authority to adopt guidelines setting limits on self-representation based upon a defendant’s mental competency. The decision recognized that a defendant can be found competent to stand trial with the assistance of an attorney, yet be too mentally unstable to represent himself.
In the Court’s majority opinion, Associate Justice Stephen Breyer wrote, “the Constitution permits judges to take realistic account of the particular defendant’s mental capacities by asking whether a defendant who seeks to conduct his own defense at trial is mentally competent to do so.”
The decision utilized arguments and research introduced in an amicus curiae (friend of the court) brief from the California-based Criminal Justice Legal Foundation.
“The Court’s decision today, clears the way for states to prevent marginally competent defendants from representing themselves at trial,” said CJLF Legal Director Kent Scheidegger. “This will help to assure that mentally ill defendants receive a competent defense while denying them the opportunity to act out their delusions before a judge and jury,” he added.
The Edwards case involves the 2005 conviction of Ahmad Edwards for attempted murder and battery. On July 12, 1999, a security guard at an Indianapolis department store caught Edwards stealing a pair of shoes. During a struggle, Edwards pulled a .40 caliber handgun and fired three shots, grazing the guard and hitting a bystander in the leg. As Edwards fled, a passing FBI agent gave chase confronting him in a parking garage. When Edwards pointed his gun at him, the agent drew his weapon and shot him in the leg. Between 1999 and 2004, Edwards, who had a long history of mental illness, was found incompetent to stand trial three times. After five years of treatment in state mental health facilities, a doctor declared him competent to stand trial with the assistance of an attorney.
At the first trial, the judge denied Edwards’ request to act as his own attorney. The jury later found him guilty of theft and criminal recklessness, but hung on the attempted murder and battery charges.
Prior to the second trial, Edwards again petitioned to represent himself. The court denied the request, citing his long history of mental illness, delusions, and communication problems. The second jury found Edwards guilty as charged, and he was sentenced to 30 years in prison.
On appeal, Edwards argued that the trial court had denied his constitutional right to represent himself. The state court of appeals agreed, overturning his conviction. In a later decision, the Indiana Supreme Court affirmed the lower court’s ruling, announcing that the U. S. Supreme Court precedent required the trial judge to grant Edwards’ request to represent himself.
When the U. S. Supreme Court agreed to hear Indiana’s appeal, CJLF filed an amicus curiae (friend of the court) brief in support. The Foundation argued that many state and federal courts, had afforded defendants the right to self-representation prior to the Faretta decision, agreed that the right could be limited to assure a fair and orderly trial. CJLF noted that the high court has allowed the states to set reasonable limits to other constitutional rights and that a requirement so rigid that trial judges are forced to allow mentally ill defendants to represent themselves undermines the public’s right to the fair and reliable administration of justice.
