Colorado v. DavisAnnotate this Case
The State charged defendant Rashaim Davis with possession and distribution of a schedule II controlled substance after Davis allegedly sold 0.372 grams of crack cocaine to an undercover detective. The State appointed a series of attorneys to represent Davis, but he refused to cooperate with any of his lawyers. He also threatened to harm at least one lawyer and wanted an investigator from the public defender's office that he might harm her if she made him uncomfortable. Several of Davis' lawyers questioned whether he was competent to proceed because at times he "exhibited a flat affect, bordering on catatonic." Prior to trial, Davis told the trial court he wanted to represent himself. Davis was taking several medications for his "bipolarism," and that he had a mistrust of lawyers resulting from paranoia that the medications did not completely control. The trial court was not convinced that Davis could proceed pro se; the case was tried with court-appointed counsel. A jury found Davis guilty of all counts. Davis appealed the trial court's denial of his requests to represent himself and his subsequent convictions to the court of appeals. The court of appeals reversed the trial court's order denying Davis' request to represent himself, citing the U.S. Supreme Court's decision in "Indiana v. Edwards," (554 U.S. 164 (2008)). The Colorado Supreme Court reversed, declining to adopt a new competency standard for mentally ill defendants pursuant to "Edwards." Furthermore, the Court reversed the appellate court's failing to order the trial court to merge Davis' possession and distribution convictions during sentencing.