United States v. Bernard, No. 11-4054 (4th Cir. 2013)Annotate this Case
Defendant appealed the district court's decision allowing him to represent himself at trial in light of the Supreme Court's decision in Indiana v. Edwards. The heightened standard discussed in Edwards, which applied when the district court considered whether to force counsel on a severely mentally ill defendant competent to stand trial who wished to represent himself, did not control. The court held that this case was more akin to Godinez v. Moran because the district court granted defendant's request to represent himself. Because the court rejected defendant's interpretation of Edwards and was satisfied that the district court applied the correct legal standard, the court affirmed the judgment.