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Criminal: Indiana Supreme Court Affirms Edwards On Remand From US Supreme Court
Posted in Litigation

Applying the United States Supreme Court’s standards for addressing a defendant's competence to act pro se at trial, the Indiana Supreme Court has unanimously affirmed the convictions of Ahmad Edwards, whose appeal to the U.S. Supreme Court last year established those standards.

The issue in Edwards v. State arose from Edwards’s convictions in connection with a 1999 theft and shooting in downtown Indianapolis.  As the Indiana Supreme Court explained, Edwards was tried twice, after the first trial resulted in a hung jury on charges of attempted murder and battery.  At his retrial, Edwards sought to proceed pro se.  The trial court found him mentally competent to stand trial under the standard in Dusky v. United States, 362 U.S. 402 (1960) (per curiam), but denied Edwards’s request to represent himself.  Edwards was convicted of both charges.

When Edwards’s appeal first reached the Indiana Supreme Court, the Court determined it was constrained by then-existing U.S. Supreme Court precedent to conclude that Edwards should have been permitted to proceed pro se.

The U.S. Supreme Court granted the State’s petition for writ of certiorari, and held:

[T]he 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. See the United States Supreme Court’s opinion in Indiana v. Edwards here.

On remand, the Indiana Supreme Court was tasked, first, with determining the standard it should apply to decide whether the trial court correctly denied Edwards’s request to represent himself.  The Court, concluding that the decision is necessarily a fact-sensitive one, held that the trial court’s determination should be reviewed under the clearly erroneous standard. The Court then had to decide whether its review should proceed on the existing record or whether a new hearing must be held to consider the issue of Edwards’s competence to represent himself as of his December 2005 trial.  The Court found the latter option untenable, and conducted its review based on the existing record from Edwards’s request to represent himself.  The Court then held that the trial court’s finding that Edwards was not competent to conduct trial proceedings by himself was supported by the record, and that Edwards was not denied his Sixth Amendment right to self-representation.

The Court then addressed Edwards’s claim that Article I, Section 13 of the Indiana Constitution granted him broader rights than the Sixth Amendment, and that the denial of his request violated those state constitutional rights.  Article I, Section 13 guarantees an accused the right “to be heard by himself and by counsel.”  Acknowledging that Article I, Section 13 grants broader rights than the Sixth Amendment with respect to representation by counsel, the Indiana Supreme Court nevertheless concluded 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 by [the U.S. Supreme Court held in Edwards’s case].”



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