People v. Johnson

Opinion

CHIN, J.

Defendants in criminal cases have a federal constitutional right to represent themselves. (Faretta v. California (1975) 422 U.S. 806 [45 L.Ed.2d 562, 95 S.Ct. 2525] (Faretta).) In Indiana v. Edwards (2008) 554 U.S. 164 [171 L.Ed.2d 345, 128 S.Ct. 2379] (Edwards), however, the United States Supreme Court held that states may, but need not, deny self-representation to defendants who, although competent to stand trial, lack the mental health or capacity to represent themselves at trial—persons the court referred to as “gray-area defendants.” (Id. at p. 174.) We must decide whether…