The Constitution does not prohibit states from requiring appointment of counsel where a defendant is not competent to represent himself due to mental illness. Prior to Edwards’ trial for murder, he was the subject of three competency hearings and two hearings regarding his request to represent himself. The trial court denied his request to represent himself, finding that although Edwards was competent to stand trial, he was not competent to defend himself at trial. He was represented by appointed counsel and convicted. Indiana’s appellate court ordered a new trial based on the denial of Edwards’ constitutional right to self-representation under the Sixth Amendment and Faretta v. California. The United States Supreme Court vacated the opinion and remanded. The Constitution does not forbid states from insisting on representation by counsel for those who suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves.