South Carolina v. Barnes
Annotate this CaseRespondent Steven Barnes' first capital conviction and sentence were reversed on appeal because he was denied his constitutional right to represent himself at trial. In that first case, the South Carolina Supreme Court declined to adopt the heightened competency standard for a defendant who seeks to represent himself which is permitted, but not required, by "Indiana v. Edwards," (554 U.S. 164 (2008)). Since the "Edwards" standard had been applied by the circuit judge in this case, the South Carolina Court held it was "constrained to reverse" respondent's conviction and sentence. The State planned to retry respondent, and indicated it would again seek the death penalty. Respondent sought the appointment of counsel to represent him in these new proceedings. At the appointment hearing, the State argued that in seeking representation for the retrial, respondent essentially conceded that his prior conviction was constitutionally obtained. The State contended that in light of this concession, respondent's original conviction and sentence should be reinstated and the Supreme Court should proceed to review the issues raised but not reached in the first appeal. The circuit court denied the State's request. The South Carolina Supreme Court, in review of this case, found that the State relied on appellate decisions that remanded the question of the defendant's waiver of his right to counsel to the trial court for reconsideration. "It is apparent to us that the State now regrets that in respondent's first appeal it chose to argue only that the trial court's adoption and application of the standard announced in Edwards, [. . .], was correct, rather than to ask in the alternative for a remand if the Court were not to adopt Edwards. The State did not seek this alternative relief, we decided the appeal on its merits, and properly returned the remittitur to the circuit court. Respondent is entitled to the new trial, with all its attendant constitutional rights, pursuant to our decision in his first appeal."
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