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Name: People v. Taylor
Case #: S054774
Court: CA Supreme Court
District CalSup
Opinion Date: 12/24/2009
Summary

Under the Sixth Amendment, a defendant who is competent to stand trial may assert his right to self-representation, irrespective of his ability to present a defense because of a mental state, if his waiver of counsel is voluntary, knowing, and intelligent. In this 1996 death penalty murder trial, proceedings were initially suspended pursuant to Penal Code section 1368, to assess appellant’s competency to stand trial. The two appointed psychologists evaluated appellant and found him to be competent to stand trial, although noted that he had some mental problems. Appellant then moved to represent himself and the request was eventually granted. Following the guilt phase, appellant was convicted. Despite the trial court’s offer to reappoint counsel for the penalty phase, appellant declined and chose to continue to represent himself and at the conclusion of the penalty phase, the jury set the penalty for death. On appeal, appellant contended that his right to a fair trial overruled his right to represent himself and because of his “inept” conduct, his trial was fundamentally unfair. The Supreme Court rejected the argument. The federal constitution is not violated when a trial court permits a mentally ill defendant to represent himself, even if he lacks the mental capacity to conduct trial proceedings, if he is competent to stand trial and his waiver of counsel is voluntary, knowing, and intelligent. Although a state, in assessing a claim for self-representation, may adopt a higher standard of mental competence for self-representation than representation with counsel at trial, due process does not require the state to do so. (Indiana v. Edwards (2008) __U.S. __ [128 S.Ct. 2379].) At the time of appellant’s trial, because California had not adopted such a second standard, the trial court did not commit federal constitutional error in granting appellant’s request to represent himself. Additionally, the record did not support appellant’s claim that the court abused its discretion in granting the self-representation request — the colloquy between appellant and the court indicated that the court adequately advised appellant of the risks of self-representation and the appellant responded in such a manner as to indicate he understood them.