People v. Sheley, 964 N.E.2d 170

Defendant Nicholas Sheley was charged with aggravated battery, aggravated assault, and criminal damage to government property while in Knox County custody.
Defense counsel was appointed; defense sought to waive counsel and proceed pro se, supported by expert reports.
Dr. Hanlon opined defendant lacked capacity to consistently represent himself; Dr. Killian deemed him fit to waive counsel and defend himself.
The trial court admonished Sheley and denied the pro se request, citing risks in the capital case and dangers of uninitiated defense.
Sheley was convicted on all counts; defense.post-trial motions raised pro se arguments of ineffective assistance; the court denied relief.
The appellate court reversed and remanded for a new trial, holding no severe mental illness established Edwards standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Edwards requires a finding of severe mental illness to deny pro se	Sheley	People	Remand; court erred in denying pro se under Edwards

Faretta v. California, 422 U.S. 806 (U.S. 1975) (right to self-representation if voluntary and intelligent)
Dusky v. United States, 362 U.S. 402 (U.S. 1960) (competence to stand trial standard)
Indiana v. Edwards, 554 U.S. 164 (U.S. 2008) (limits on self-representation when severe mental illness)
Lego v. People, 168 Ill. 2d 561 (Ill. 1995) (prior rule permitting pro se with fitness and waiver)
Ji v. State, 316 S.W.3d 860 (Tex. Ct. App. 2010) (example denying pro se due to mental illness)
State v. McNeil, N.J. Super. 39, 963 A.2d 358 (N.J. Super. Div. App. 2009) (severe mental illness justification for denial)
State v. Lewis, 280 Neb. 246, 785 N.W.2d 834 (Neb. 2010) (schizophrenia with disruptive outburst did not permit pro se)