554 U.S. 164 (2008)
In July 1999 Ahmad Edwards tried to steal a pair of shoes from an Indiana department store.1 After being discovered he drew a gun, fired at a store security officer, and wounded a bystander.2 He was charged with attempted murder, battery with a deadly weapon, criminal recklessness, and theft.3 Edwards was diagnosed with schizophrenia, and his mental condition became the subject of three competency proceedings and two self-representation requests, mostly before the same trial judge.4
In August 2000 the court found Edwards incompetent to stand trial after hearing psychiatrist and neuropsychologist witnesses and committed him to Logansport State Hospital.5 In March 2002 the court held another competency hearing, considered additional psychiatric evidence, and found Edwards competent to stand trial despite suffering from mental illness.6 In April 2003 the court held a third competency hearing, received further evidence of serious thinking difficulties and delusions, and again found Edwards incompetent, ordering his recommitment to the state hospital.7
In 2005 the hospital reported that Edwards had again become competent to stand trial.8 Just before his first trial in June 2005 Edwards asked to represent himself and requested a continuance, which the court refused; he proceeded with appointed counsel and was convicted of criminal recklessness and theft, but the jury deadlocked on the attempted murder and battery charges. The State retried Edwards on the remaining charges.9 Before the December 2005 retrial Edwards again asked the court to permit him to represent himself.10 The trial court, referring to the lengthy record of psychiatric reports, denied the request.
Edwards appealed to the Indiana Court of Appeals, which reversed his convictions. The Indiana Supreme Court affirmed.11 The U.S. Supreme Court granted certiorari.12
Whether the Constitution permits a State to limit a defendant’s right to represent himself at trial by insisting upon representation by counsel when the defendant is competent to stand trial but, because of severe mental illness, is not competent to conduct trial proceedings by himself?13
The Constitution permits a State to limit a defendant’s right to represent himself at trial by insisting upon representation by counsel when the defendant is competent to stand trial but, because of severe mental illness, is not competent to conduct trial proceedings by himself.14 This rule recognizes that the right of self-representation established in Faretta is not absolute.15 Trial judges may account for the particular defendant's mental capacities when severe mental illness impairs the ability to conduct trial proceedings even if the Dusky standard for standing trial is met.16
Yes. The established facts demonstrate that Edwards was found competent to stand trial in March 2002 and again in 2005 after multiple periods of incompetence stemming from schizophrenia.17 The trial court denied his self-representation requests in both the June 2005 trial and the December 2005 retrial after reviewing the extensive psychiatric record showing fluctuating competency, delusions, and incoherent efforts at self-representation.18 This denial is constitutionally permissible because the Dusky standard focuses on the ability to consult with counsel and understand proceedings, whereas self-representation demands additional capacities for organizing a defense, examining witnesses, and maintaining courtroom order that mental illness can impair without violating the right to a fair trial.19
The Constitution permits a State to limit the defendant's right to self-representation when the defendant is competent to stand trial but not competent to conduct trial proceedings by himself due to severe mental illness.20
Related opinions on this issue
Joined by Justice Thomas
Justice Scalia dissented on the ground that once a defendant is found competent to stand trial and knowingly and voluntarily waives the right to counsel, the Sixth Amendment guarantees the right to self-representation without further limitation based on mental illness.21 He argued that the majority improperly introduced a paternalistic exception allowing the State to override the defendant's autonomous choice to present his own defense.22 Scalia maintained that the only permissible basis for denying self-representation remains deliberate obstructionist misconduct rather than a judicial assessment of the defendant's mental fitness to conduct the trial.23