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Monday, May 21, 2007

Ind. Decisions - "As it stands today, we are bound by these authorities as Supreme Court precedent"

Here is a quote from our Supreme Court's May 17th decision in Ahmad Edwards v. State:

Here we have a determination by an experienced trial judge that Edwards was incapable of presenting a defense. That determination is necessarily based on factors better evaluated by, as Justice Breyer put it, “judges closer to the firing line.” Martinez, 528 U.S. at 164. We have sympathy for the view that a trial court should be afforded some discretion to make that call. The record in this case presents a substantial basis to agree with the trial court and thus presents an opportunity to revisit the holdings of Faretta and Godinez, if the Supreme Court of the United States decides that is to be done. However, as it stands today, we are bound by these authorities as Supreme Court precedent. Accordingly, we hold that because Edwards was found competent to stand trial he had a constitutional right to proceed pro se and it was reversible error to deny him that right on the ground that he was incapable of presenting his defense.
Today Jon Murray of the Indianapolis Star writes:
The state's efforts to keep a schizophrenic Indianapolis man from representing himself at his trial could end up under review by the U.S. Supreme Court.

Lawyers for Indiana's attorney general are studying a state Supreme Court ruling last week that overturned Ahmad Edwards' convictions for attempted murder and battery. He had tried repeatedly to spurn his public defenders and represent himself in a case that stemmed from a lunch-hour shooting outside Circle Centre mall.

But a Marion Superior Court judge denied those requests. Judge Grant Hawkins found Edwards competent to be tried but not to represent himself, ruling that his mental health problems would make an adequate defense too difficult.

The Indiana Supreme Court ordered a new trial, echoing a similar Indiana Court of Appeals ruling issued in September.

Both cited U.S. Supreme Court decisions that make it clear defendants can represent themselves as long as they are found competent to stand trial and understand the consequences they face.

No other restrictions apply -- though the Indiana justices signaled the case might be ripe to challenge the previous rulings that forced them to side with Edwards.

A sidebar to the Star story notes:
The Indiana Supreme Court relied primarily on two U.S. Supreme Court rulings.

In Faretta v. California (1975), it ruled defendants can "knowingly and intelligently" give up their right to an attorney.

In Godinez v. Moran (1993), it established that defendants must be competent to waive their right to an attorney, but not competent enough to represent themselves.

Here are the earlier ILB entries, from May 17th and May 18th.

Posted by Marcia Oddi on May 21, 2007 09:45 AM
Posted to Ind. Sup.Ct. Decisions