The U.S. Supreme Court case Indiana v. Edwards (2007) revolved around the issue of whether a defendant who is competent enough to stand trial, but suffers from severe mental illness, has the right to represent himself in court proceedings. Ahmad Edwards was charged with attempted murder and theft in Indiana state court and sought to represent himself at his trial despite having been diagnosed with schizophrenia. The trial judge denied this request on grounds that he lacked sufficient mental capacity for self-representation due to his illness, even though he met the standard for competency to stand trial as established by Dusky v United States (1960). On appeal, the Supreme Court upheld this decision stating that states may insist upon representation by counsel for those competent enough to stand trial under Dusky but who still suffer from severe mental illness such that they are not competent enough for self-representation.

In the dissenting opinion for Indiana v. Edwards, Justice Antonin Scalia argued that the majority's decision to allow states to insist upon representation for defendants who are competent enough to stand trial but not represent themselves contradicts previous rulings of the court. He contended that this ruling undermines a defendant's autonomy and right to control their defense as established in Faretta v. California (1975). Furthermore, he criticized the majority’s reliance on amicus briefs from psychiatric associations rather than legal precedent or constitutional text. Scalia also expressed concern about potential misuse of this ruling by judges who may prefer dealing with lawyers over pro se defendants, leading them to deny self-representation based on questionable competency evaluations.