Wilson v. ColoradoAnnotate this Case
Petitioner Douglas Wilson was charged with first degree murder. He was appointed a public defender, but citing a conflict of interest, Wilson insisted upon new representation. The trial court determined that Wilson either had to keep the same lawyer or represent himself. Wilson opted to represent himself with assistance from advisory counsel. At a subsequent hearing, a question over Wilson's competency to stand trial became an issue. After being deemed competent as long as he was on his medications, Wilson went through two more attorneys until six days prior to trial when Wilson alleged he was no longer competent to stand trial. The trial court disagreed with Wilson's allegations, and he continued to represent himself with limited help. A jury ultimately found him guilty. Wilson appealed his conviction through counsel, and the court of appeals affirmed the conviction. Petitioner William Beaty was charged with assault, criminal mischief, tampering with a victim or witness, and intimidating a victim or witness. A public defender was appointed to represent Beaty, but that counsel was dismissed and Beaty elected to represent himself. After his Arguello advisement, Beaty chose not to represent himself, and accepted the help of a public defender. Beaty stated that his original decision to proceed pro se was due in part to his failing to take his medications to control bipolar disorder and schizophrenia. On the first day of trial, Beaty expressed a renewed desire to represent himself due to a conflict with his public defender. Beaty represented himself throughout the trial, and a jury found him guilty of all charges. The Colorado Supreme Court granted certiorari in Williams' and Beaty's cases to determine whether to adopt a new competency standard for mentally ill defendants in light of "Indiana v. Edwards," (554 U.S. 164 (2008)). The Court declined to create a new standard, and affirmed the court of appeals' decisions to retain the existing analytical framework.