Smith's Criminal Case Compendium
Smith's Criminal Case Compendium
Table of Contents
Smith's Criminal Case Compendium
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This compendium includes significant criminal cases by the U.S. Supreme Court & N.C. appellate courts, Nov. 2008 – Present. Selected 4th Circuit cases also are included.
Jessica Smith prepared case summaries Nov. 2008-June 4, 2019; later summaries are prepared by other School staff.
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The defendant was competent to stand trial and to represent himself. As to competency to stand trial, the defendant had several competency evaluations and hearings; the court rejected the defendant’s argument that a report of the one doctor who opined that he was incompetent was determinative of the issue, noting that numerous other doctors opined that he was malingering. The court also rejected the defendant’s argument that even after several competency hearings, the trial court erred by failing to hold another competency hearing when the defendant disrupted the courtroom, noting in part that four doctors had opined that the defendant’s generally disruptive behavior was volitional. The court also rejected the defendant’s argument that even if he was competent to stand trial, the trial court erred by allowing him to proceed pro se. The court found Indiana v. Edwards inapplicable because here--and unlike in Edwards--the trial court granted the defendant’s request to proceed pro se. Also, the defendant did not challenge the validity of the waiver of counsel colloquy.
Based on assessments from mental health professionals and the defendant’s own behavior, the trial court did not abuse its discretion by ruling that the defendant was competent to represent himself at trial.
No violation of the defendant’s Sixth Amendment right to counsel occurred when the trial court found that the defendant forfeited his right to counsel because of serious misconduct and required him to proceed pro se. The court rejected the defendant’s argument that Indiana v. Edwards prohibits a finding of forfeiture by a “gray area” defendant who has engaged in serious misconduct.
This capital case came back before the N.C. Supreme Court after that court remanded in State v. Lane,362 N.C. 667 (Dec. 12, 2008) (Lane I), for consideration under Indiana v. Edwards, 554 U.S. 164 (2008), as to whether the trial judge should have exercised discretion to deny the defendant’s request to represent himself. Edwards held that states may require counsel to represent defendants who are competent to stand trial but who suffer from severe mental illness to the extent that they are not competent to represent themselves. At trial, the trial court had accepted the defendant’s waiver of counsel and allowed the defendant to proceed pro se. Following a hearing, held on remand after Lane I, the trial court concluded that the defendant was competent to stand trial and to discharge his counsel and proceed pro se. The N.C. Supreme Court held that because the defendant never was denied his constitutional right to self-representation (he was allowed to proceed pro se), the U.S. “Supreme Court’s holding in Edwards, that the State may deny that right if a defendant falls into the “gray area” of competence, does not guide our decision here.” Slip op. at 22. Rather, the N.C. Supreme Court clarified, because the trial court found the defendant competent to stand trial, the issue was whether the defendant made a knowing and voluntary waiver of his right to counsel. On that issue, and after a detailed review of the trial court’s findings, the court concluded that the trial court’s inquiry was sufficient to support its determination that the defendant knowingly and voluntarily waived his right to counsel. In the course of that ruling, the court reaffirmed that a defendant’s technical legal knowledge is not relevant to an assessment of a valid waiver of counsel.
While Lane I could be read to suggest that the trial court always must undertake an Edwards inquiry before allowing a defendant to proceed pro se, Lane II suggests otherwise. In Lane II, the court clarified the options for the trial court, stating:
For a defendant whose competence is at issue, he must be found [competent] before standing trial. If that defendant, after being found competent, seeks to represent himself, the trial court has two choices: (1) it may grant the motion to proceed pro se, allowing the defendant to exercise his constitutional right to self-representation, if and only if the trial court is satisfied that he has knowingly and voluntarily waived his corresponding right to assistance of counsel . . . ; or (2) it may deny the motion, thereby denying the defendant’s constitutional right to self-representation because the defendant falls into the “gray area” and is therefore subject to the “competency limitation” described in Edwards. The trial court must make findings of fact to support its determination that the defendant is “unable to carry out the basic tasks needed to present his own defense without the help of counsel.” 365 N.C. at 22 (citations omitted).
The trial court did not err in allowing the defendant to represent himself after complying with the requirements of G.S. 15A-1242. The court rejected the defendant’s argument that his conduct during a pre-trial hearing and at trial indicated that he was mentally ill and not able to represent himself, concluding that the defendant’s conduct did not reflect mental illness, delusional thinking, or a lack of capacity to carry out self-representation under Indiana v. Edwards, 128 S. Ct. 2379 (2008).