SCOTUS holds that states may require defendants with limited capacity to be represented by counsel

In Indiana v. Edwards, the Supreme Court decided an issue regarding self-representation. The case focused upon a criminal defendant whom a state court found mentally competent to stand trial if represented by counsel but not mentally competent to conduct the trial himself. The Supreme Court granted certiorari to determine the relation of mental competency to the right of self-representation. The Court ultimately held that a state may limit a defendant’s self-representation right by insisting upon counsel at trial on the ground that the defendant lacks the mental capacity to conduct his trial defense alone. The Court recognized that a trial judge has much discretion when making the determination about a defendant’s capacity to represent himself. According to the Court, the Constitution permits states to insist upon representation by counsel for those competent enough to stand trial but who still suffer from severe mental illness to the point where they are not competent to conduct the trial proceedings by themselves.