State v. Lane
| Decision Date | 12 December 2008 |
| Docket Number | No. 606A05.,606A05. |
| Court | North Carolina Supreme Court |
| Parties | STATE of North Carolina v. Eric Glenn LANE. |
defendant guilty of first-degree murder. On 20 March 2008, the Supreme Court allowed defendant's motion to bypass the Court of Appeals as to his appeal of additional judgments. Heard in the Supreme Court on 17 November 2008.
Roy Cooper, Attorney General, by Robert C. Montgomery, Special Deputy Attorney General, and Derrick C. Mertz, Assistant Attorney General, for the State.
Ann B. Petersen, Chapel Hill, for defendant-appellant.
The trial court entered judgment imposing the jury's capital sentence in this case on 11 July 2005. The Supreme Court of the United States decided Indiana v. Edwards on 19 June 2008. ___ U.S. ___, 128 S.Ct. 2379, 171 L.Ed.2d 345 (2008). Based on Edwards, defendant argues on appeal that he is entitled to a new trial because the trial court was unaware of its discretion to deny defendant's request for self-representation, and that if it had been aware of its discretion, the trial court would have required counsel for defendant. In light of Edwards, this case is remanded to the Superior Court, Wayne County, for further hearing by the presiding trial judge to determine the following issues:
(1) At the time defendant sought to represent himself in this matter, did he come within the category of "borderline-competent" (or "gray-area") defendants, id. at ___, 128 S.Ct. at 2384-85, 171 L.Ed.2d at 353-55, defined by the Supreme Court of the United States as parties "competent enough to stand trial under Dusky [v. United States, 362 U.S. 402, 80 S.Ct. 788, 4 L.Ed.2d 824 (1960) (per curiam)] but who still suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves"? Edwards, ___ U.S. at ___, 128 S.Ct. at 2388, 171 L.Ed.2d at 357.
Only if the first inquiry is answered in the affirmative should the trial court proceed to this second issue:
(2) Given that the United States Constitution permits judges to preclude self-representation for defendants adjudged to be "borderline-competent" based on a "realistic account of the particular defendant's mental capacities," id. at ___, 128 S.Ct. at 2387-88, 171 L.Ed.2d at 357, the court...
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State v. Connor, No. 18099.
...trial court for determination of whether that court "would have operated differently with the benefit of Edwards"); State v. Lane, 362 N.C. 667, 668, 669 S.E.2d 321 (2008) (case remanded to trial court for hearing to determine whether "the court in its discretion would have precluded self-r......
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State Carolina v. Eric Glenn Lane.
...After hearing oral argument on 17 November 2008, the Supreme Court issued an opinion on 12 December 2008, State v. Lane, 362 N.C. 667, 669 S.E.2d 321 (2008) (per curiam), as clarified by an order entered on 9 March 2009, remanding the case to the trial court for further hearings, findings o......
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Short v. North Carolina
...to be 'borderline-competent' based on a 'realistic account of the particular defendant's mental capacities....' " State v. Lane, 669 S.E.2d 321, 322 (N.C. 2008) (quoting Indiana v. Edwards, 554 U.S. 164, 177-78 (2008). In short, state courts in North Carolina and other jurisdictions routine......
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State v. Lytle, No. COA09-1427 (N.C. App. 6/15/2010)
...be `borderline-competent' based on a `realistic account of the particular defendant's mental capacities . . . .'" State v. Lane, 362 N.C. 667, 668, 669 S.E.2d 321, 322 (2008) (quoting Edwards, ___ U.U. at ___, 128 S. Ct. at 2387-88, 171 L. Ed. 2d at 357 (2008), clarified, 363 N.C. 121, ___ ......