Indiana v. Edwards

Edwards was convicted of attempted murder and battery with a deadly weapon in Indiana state court. After he was arrested in 1999, Edwards was deemed to be schizophrenic, and the trial court declared him incompetent to stand trial on two separate occasions. Finally, in 2004, Edwards was found competent to stand trial. However, the trial court denied Edwards' request to represent himself at trial because he lacked the capacity to adequately defend himself, even though he was competent to stand trial,. Edwards appealed his conviction, claiming that he was denied his Sixth Amendment right to self-representation. The court of appeals agreed and ordered a retrial. The State then asked that the case be transferred to the Indiana Supreme Court for further consideration.

The Indiana Supreme Court affirmed the court of appeals' decision, holding that the federal constitutional right to self-representation requires that a defendant who is competent to stand trial be permitted to represent himself. The Court relied on the fact that the Supreme Court of the United States had previously held that competency to represent oneself at trial is measured by competency to stand trial.

Question Presented

May States adopt a higher standard for measuring competency to represent oneself at trial than for measuring competency to stand trial?

Decision under Review

Supreme Court Opinion