Indiana v. Edwards (2007)

Docket
07-208
Decided
2007-01-01

Summary

Question: Does the Court's prior ruling that a criminal defendant need only be "literate, competent, and understanding" to represent himself at trial set an appropriate standard for defining that defendant's mental competence to invoke his Sixth Amendment right to self-representation when he is otherwise unable to conduct a coherent defense? Conclusion: No. In a 7-2 opinion, the Court held that the Constitution does not forbid states from insisting upon representation for those competent to stand trial but who suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves. The Court noted that Faretta only affirmed the right to self representation when the individual "voluntarily and intelligently elects to do so," and therefore does not apply when that individual's mental competency is called into question. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented, stating that in his view the Constitution does not permit a state to substitute its own perception of fairness for the defendant's right to make his own case before the jury, even if the defendant does have questionable mental competence.

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