Chadwick v. State

In Chadwick v. State, 277 S.W.3d 99 (Tex. App.-Austin 2009), aff'd, 309 S.W.3d 558, 2010 WL 1780053, the trial court found Chadwick incompetent to stand trial for charges of attempting to take a weapon from a peace officer and assault on a public servant. Id. at 101-02. The trial court ordered Chadwick committed to a state hospital, and after his competency to stand trial was restored, the court denied his request for self-representation. Id. at 102. He was represented by counsel at trial, and the jury found him guilty. Id. On appeal, he argued "that the trial judge improperly refused to allow him to proceed pro se after his competency to stand trial was restored." In affirming the trial court's ruling, the court of appeals stated, in relevant part: The trial court had sufficient evidence before it to support a finding that Chadwick was incompetent to represent himself. At the . . . pre-trial hearing and on the first day of trial, Chadwick interrupted his attorney several times and personally argued several motions that his attorney did not adopt. This gave the trial court the opportunity to observe the extent of Chadwick's ability to conduct his own defense at trial. Chadwick jumped from one topic to another, devoted most of his time to ad hominem attacks on the prosecutor, the judge, the bailiffs, judges from his prior cases, and other county and state officials. Many of his arguments were simply conclusory, while others were incoherent. . . . The trial court also had before it several incoherent written motions that Chadwick had filed pro se. Given all of the foregoing, the trial court could have reasonably concluded that Chadwick was not competent to represent himself and that, if he had been allowed to do so, he would not have been able to receive a fair trial. (Chadwick, 277 S.W.3d at 104-05.) Chadwick argued to the court of criminal appeals that the Austin Court of Appeals erred (1) in its application of Indiana v. Edwards . 554 U.S. 164 (2008) and (2) by implying findings of fact supporting the trial court's ruling. In affirming the appellate court, the court of criminal appeals noted that the appellate court "correctly observed that Indiana v. Edwards controlled the case, and that under Indiana v. Edwards, the individual States may insist that a defendant who is competent to stand trial-but incompetent to conduct his or her own defense-be represented by counsel." The court of criminal appeals also stated that "the evidence in this case supported implied findings of fact that Chadwick's mental illness was severe enough to render him incompetent to proceed pro se, even though the trial judge deemed competent him to stand trial." The court noted that at the pretrial hearing, "Chadwick objected several times, even as the judge granted the motions filed by his attorney. . . ." Id. At the end of the pretrial hearing, Chadwick asked the trial court, "'Would it be inappropriate to curse you with every Israeli curse there is?'" Id. Chadwick, ignoring his counsel's advice not to curse the judge, stated, "'May Yahweh curse you till the end and may I put an eternal indictment on you and I will prosecute you to eternity.'" Id. Chadwick also refused to come to court on the day trial was set to begin. Id. He came to court only after he was allowed to make a video in the jail, documenting various grievances. Id. The court of criminal appeals stated that based upon the evidence--Chadwick's behavior before the trial court, his refusal to come to court on the first day of his trial, and the incoherent pro se motions, and viewing the evidence in the light most favorable to the trial court's ruling, "we conclude that the judge did not abuse his discretion." Id. The court held "that the court of appeals did not err in implying findings of fact supporting the trial judge's decision to deny Chadwick's request to represent himself." Id.