Tuesday, March 17, 2009
Ind. Decisions - Supreme Court decides Ahmad Edwards v. State, on remand from SCOTUS
Here is a quote from our Supreme Court's May 17, 2007 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.The case went to the Supreme Court of the United States. The Court issued its decision June 19, 2008. Here, from the end of the majority SCOTUS opinion in Indiana v. Edwards:
We consequently conclude that 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. That is to say, the Constitution permits States to insist upon representation by counsel for those competent enough to stand trial under Dusky but who still suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves.Here are some ILB entries from June 19, 2008 (one and two) and the 20th. Here are earlier ILB entries, leading up to the SCOTUS decision.
Indiana has also asked us to adopt, as a measure of a defendant’s ability to conduct a trial, a more specific standard that would “deny a criminal defendant the right to represent himself at trial where the defendant cannot communicate coherently with the court or a jury.” We are sufficiently uncertain, however, as to how that particular standard would work in practice to refrain from endorsing it as a federal constitutional standard here. We need not now, and we do not, adopt it.
Indiana has also asked us to overrule Faretta. We decline to do so. * * *
For these reasons, the judgment of the Supreme Court of Indiana is vacated, and the case is remanded for further proceedings not inconsistent with this opinion.
In Ahmad Edwards v. State, On Remand from the Supreme Court of the United States , a 10-page, 5-0 opinion issued today, Justice Boehm writes:
We hold that the record supports a finding by the trial court that the defendant suffered from a severe mental illness to the point where he was not competent to conduct trial proceedings by himself. The denial of the defendant’s request to act pro se at trial therefore did not violate either his federal or state constitutional right to self-representation. * * *
I. The Sixth Amendment Claim. We understand Edwards to announce the following rule of law: a trial court may deny a defendant’s request to act pro se when the defendant is mentally competent to stand trial but suffers from severe mental illness to the point where he is not competent to conduct trial proceedings by himself. In this case, Edwards was found mentally competent to stand trial, but the trial court denied his request to proceed pro se. The questions we face on remand, therefore, are whether the trial court found that Edwards suffered from a severe mental illness such that he was not competent to conduct trial proceedings on his own, and, if so, whether the record supports this finding. * * *
Edwards’s psychiatric evaluations at times disagree, but they overwhelmingly confirm that Edwards has suffered from severe and pervasive mental illness. And though the trial court did not rely on any psychiatric evaluations completed after July of 2004, the trial judge had the opportunity to observe Edwards at his July trial. The trial court also had the lengthy record of Edwards’s mental disorders and the discordant motions that Edwards submitted, some immediately preceding his retrial. Finally, the trial court had before it the record of erratic performance that gave no confidence that whatever Edwards’s state as of a given moment, it might be a transient condition. Taken together, these circumstances support the trial court’s determination that Edwards suffered from severe mental illness such that he was not competent to represent himself. We therefore affirm the judgment of the trial court.
II. The Indiana Constitutional Claim. Edwards urges us to find broader self-representation rights under the Indiana Constitution than those afforded by the federal constitution. Edwards contends that there is a "firmer foundation" for the right of self-representation under article I, section 13 which guarantees an accused the right "to be heard by himself and by counsel." * * *
We think that the right to self-representation of mentally impaired persons under section 13 is no broader than that guaranteed by the Sixth Amendment as interpreted in Edwards. * * *
Conclusion. The trial court’s denial of Edwards’s request to proceed pro se was justified by the record and did not violate Edwards’s right to self-representation under either the Sixth Amendment or article I, section 13. Edwards’s convictions of attempted murder and battery are affirmed.
Posted by Marcia Oddi on March 17, 2009 10:18 AM
Posted to Ind. Sup.Ct. Decisions