Westbrook v. Arizona

finding of competency to stand trial is not dispositive of issue of competency to waive counsel | finding of competency to stand trial is not dispositive of issue of competency to waive counsel | granting motion for leave to proceed in forma pauperis and petition for writ of certiorari | cautioning trial courts in their analysis of a defendant’s waiver of “fundamental, clear-cut rights” | stating defendant must not only desire to represent himself, but also be competent to waive his right to counsel; court is required to make a waiver determination | discussing competency to waive constitutional right to assistance of counsel and conduct a defense | "`This protecting duty imposes the serious and weighty responsibility upon the trial judge of determining whether there is an intelligent and competent waiver by the accused' " | “ ‘This protecting duty imposes the serious and weighty responsibility upon the trial judge of determining whether there is an intelligent and competent waiver by the accused’ ” | exclusion of third-party evidence in double homicide error; defendant proffered evidence of mixture of third-party’s blood, blood of one victim on defendant’s shoes | although court had decided defendant was competent to stand trial, further “inquiry into the issue of his competence to waive his constitutional right to the assistance of counsel” was necessary | competency necessary to represent self greater than competency necessary to stand trial | competency necessary to represent self greater than competency necessary to stand trial | comparing competency to stand trial with competency to waive counsel | competence to waive assistance of counsel at trial