Attempted Murder for Discharging a Firearm - Example Case
In Indiana v. Edwards (2008) 554 U.S. 164, the defendant was charged with attempted murder for discharging a firearm at a security officer and wounding a bystander when he was discovered trying to steal a pair of shoes from a department store. Edwards, who suffered from schizophrenia, was the subject of three competency proceedings.
In two of the three competency proceedings, the court determined Edwards was not competent to stand trial, and in the last hearing at which he was found not competent, a psychiatrist testified that Edwards could understand the charges against him, "but he was 'unable to cooperate with his attorney in his defense because of his schizophrenic illness'; 'his delusions and his marked difficulties in thinking make it impossible for him to cooperate with his attorney.'" (Indiana v. Edwards, supra, 554 U.S. at p. 168.)
Edwards made two requests to represent himself at trial. After enumerating the lengthy record of psychiatric reports in the case, the trial court concluded that although Edwards was now competent to stand trial, he was not competent to represent himself. The subsequent judgment of conviction was reversed on appeal and affirmed by the State Supreme Court on the basis that once Edwards was competent to stand trial, under Faretta, Edwards could not be prohibited from exercising his right to self-representation. (Indiana v. Edwards, supra, 554 U.S. at p. 169.)
On review, the U.S. Supreme Court considered whether state courts could deny the right to self-representation to a defendant with a history of mental illness after the defendant was deemed competent to stand trial.
Edwards holds "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 v. United States (1960) 362 U.S. 402 but who still suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves." (Indiana v. Edwards, supra, 554 U.S. at pp. 177-178.)