Adams v. State

I join in the court’s opinion, which, as I understand it, stands for the limited proposition that a person suffering from paranoid schizophrenia cannot be permitted to waive counsel when the person’s delusional system encompasses defense counsel and thus influences the decision to proceed pro se. This proposition finds support in the case law. See, e.g., People v. Burnett, 188 Cal.App.3d 1314, 234 Cal.Rptr. 67 (1987); *1207State v. Bauer, 245 N.W.2d 848 (Minn.1976).2

Our decision should not be read to suggest that the standard for. determining competency to waive procedural rights such as the right…