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Name: People v. Johnson
Case #: S188619
Court: CA Supreme Court
District CalSup
Opinion Date: 01/30/2012

A defendant can be found competent to stand trial but not competent to present his own defense. In Indiana v. Edwards (2008) 554 U.S. 164, the United States Supreme Court held that states may, but are not required to, deny self-representation to defendants who, although competent to stand trial lack the mental health or capacity to represent themselves at trial. In this case, the California Supreme Court concluded that California courts may deny self-representation when the United States Constitution permits them to do so, as it does in Edwards, supra, without violating the right to self-representation under Faretta v. California (2008) 554 U.S. 164, and, because California law provides no statutory or constitutional right of self-representation, such denial does not violate state law. The standard in assessing a defendant’s competency to represent himself is that suggested by Edwards; i.e., competence to represent oneself is the ability “to carry out the basic tasks needed to present [one’s] own defense without the help of counsel,” and states may “deny self-representation to those competent to stand trial but who ‘suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves.'”