Tuesday, November 5, 2013

Indiana v. Edwards case brief

Indiana v. Edwards case brief summary
554 U.S. 164 (2008)

Petitioner State charged respondent with attempted murder, battery with a deadly weapon, criminal recklessness, and theft. Eventually, respondent was found competent to stand trial and was convicted on two counts. During a retrial, respondent's Sixth Amendment self-representation request was denied and he was convicted on the remaining counts. The appellate court ordered a new trial. The Indiana Supreme Court affirmed. The State sought review.

Respondent tried to steal a pair of shoes from a department store, drew a gun, fired at a store security officer, and wounded a bystander. Respondent initially was found incompetent to stand trial and was committed to a state hospital. After being found competent, respondent was recommitted. Subsequently, respondent was found competent to stand trial and requested to represent himself at trial. The trial court found that respondent was competent to stand trial, but found that he was not competent to defend himself. Respondent was represented by appointed counsel at his retrial.

  • Under the Sixth and Fourteenth Amendments, the United States Supreme Court determined that a new trial was not warranted based on the denial of his self-representation request because the United States Constitution did not forbid the State from insisting that respondent proceed to trial with counsel, thereby denying him the right to represent himself. 
  • The United States Constitution permitted the State to limit respondent's self-representation right by insisting upon representation by counsel at trial on the ground that he lacked the mental capacity to conduct his trial defense unless represented.

The Court vacated the judgment of the state supreme court and remanded the case for further proceedings. 7-2 decision; 1 dissent.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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