People v. Davis

11 We consider whether to adopt, pursuant to the United States Supreme Court's decision in Indiana v. Edwards, 554 U.S. 164, 128 S.Ct. 2879, 171 L.Ed.2d 345 (2008), a new competency standard for mentally ill defendants who wish to waive the Sixth Amendment right to counsel. We decline to create such a standard because our existing two-part framework for determining whether a defendant has validly waived the right to counsel affords trial courts sufficient discretion to consider a defendant's mental illness. As such, we reverse the court of appeals' decision to create a new standard in light…