Melvin Eugene Fletcher v. State, 474 S.W.3d 389

Fletcher was indicted for felony theft of metal with two prior felonies alleged for enhancement; attorney Jamie Sulla was appointed and later withdrew.
Multiple competency evaluations were ordered after counsel reported communication problems; psychologist Dr. Stephen McCary twice evaluated Fletcher (who largely refused to participate) and found him competent to stand trial, diagnosing mild-to-moderate mental illness and malingering.
Fletcher filed pro se Faretta-style waivers and numerous handwritten motions asserting Moorish-nationality/jurisdictional defenses and seeking to represent himself.
The trial court conducted a Faretta hearing, admonished Fletcher on charges, punishment range, and dangers of self-representation, found the waiver valid, and allowed him to proceed pro se.
At trial Fletcher pursued jurisdictional theories before voir dire but conducted cross-examination of witnesses and argued deficiencies in the State’s proof at closing; a jury convicted him and the court found enhancements true, sentencing him to seven years.
On appeal Fletcher challenged (1) validity of his waiver of counsel and (2) the court’s decision permitting him to represent himself given his mental state; the court affirmed.

Issue	Fletcher's Argument	State's Argument	Held
Whether Fletcher’s waiver of counsel was competent, knowing, intelligent, and voluntary	Waiver invalid because court failed to advise him of possible defenses/mitigating circumstances and should have inquired further into competency after he advanced an invalid defensive theory and was medicated	Faretta hearing included requisite admonitions (charge, range of punishment, dangers of self-representation); Fletcher had been found competent to stand trial; no coercion shown	Waiver was valid; trial court’s questions/admonitions were sufficient; issue overruled
Whether the trial court abused its discretion by allowing Fletcher to represent himself given mental illness	Under Edwards, court should have insisted on counsel if severe mental illness made him unable to conduct trial proceedings; court thus abused discretion by not conducting separate inquiry	Edwards permits (but does not require) courts to insist on counsel for severely mentally ill defendants; Fletcher was already found competent to stand trial and McCary found only mild-to-moderate illness; Fletcher’s trial performance showed ability to conduct basic tasks	No abuse of discretion; no separate constitutional inquiry was required beyond competence to stand trial, and record supports implied finding he could conduct his own defense

Gideon v. Wainwright, 372 U.S. 335 (right to counsel applies to states)
Faretta v. California, 422 U.S. 806 (defendant has constitutional right to self-representation)
Godinez v. Moran, 509 U.S. 389 (competence standard for waiver of counsel is competence to waive, not to represent)
Indiana v. Edwards, 554 U.S. 164 (States may insist on counsel for defendants with severe mental illness who are nevertheless competent to stand trial)
Blankenship v. State, 673 S.W.2d 578 (Tex. Crim. App.) (trial court erred in denying self-representation based on lack of legal proficiency)
Collier v. State, 959 S.W.2d 621 (Tex. Crim. App.) (standards for determining valid waiver of counsel)