The United States Supreme Court held that a criminal defendant who has been determined competent to stand trial is not necessarily competent to represent himself at trial and can therefore be prevented from doing so by the State.
Indiana v. Edwards, 128 S. Ct. 2379 (2008).
The United States Constitution Allows a State to Limit the Right of a Criminal Defendant to Represent Himself at Trial on the Ground of a Lack of Mental Competence: Indiana v. Edwards,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol47/iss2/11