Offering a dramatic apology in court for his actions, Jeffrey Edwards pleaded guilty to four counts of indecency with a child He received a five-year sentence.
Later, Edwards petitioned for a new trial, arguing that he was not competent when he pled, and that he was pressured by his attorney to plead guilty. To bolster his claim, Edwards offered the testimony of Dr. Gold, who said that Edwards suffered from a Cluster C Personality Disorder, which caused him to avoid conflict and take responsibility for things when confronted even if he was not involved. Dr. Gold testified that Edwards would buckle to counsel's advice to plead guilty if pressured. Edwards asserted he capitulated to the claimed threats from his attorney and pled guilty. His later motion for a new trial was denied. Edwards appealed.
Holding: Affirmed. The Court held that even if Edwards' evidence had tended to establish legal incompetence, the trial court was entitled to weigh that evidence against the record from his guilty plea. This included the trial court's observations of Edwards at the time of the plea. The trial court's decision hinged on the fact that it had advised Edwards that no punishment recommendation had been provided. Further, Edwards stated orally and in writing that his plea was voluntary, and that he had not been promised anything in exchange for the plea. Finally, Edwards had stated he was satisfied in all respects with his counsel's representation. The court also considered Edwards' written statement admitting the offense prior to coming into contact with his allegedly abusive attorney, negating his theory that he was taking responsibility under pressure for something he had not done. Based upon all the facts, the trial court acted within its discretion in denying a new trial.
The Last Word: Edwards' father testified that he had advised Edwards not to plead guilty, according to prosecutor Tom Darnold. The trial court had found that this testimony conflicted with Edwards' assertion that he could not stand up to authority, or would capitulate if confronted, and was a significant factor in the courts finding that Edwards' claimed submission to threats by his attorney was not credible.
 | Michael First, M.D. Psychiatrist The Forensic Panel |
Dr. First comments: A personality disorder is defined in DSM-IV as "an enduring pattern of inner experience and behavior that deviates markedly from the expectations of the individual's culture, is pervasive and inflexible, has an onset in adolescence or early adulthood, is stable over time, and leads to distress or impairment." (DSM-IV, page 629). There are major questions regarding whether Edwards' asserted pattern is truly pervasive enough to consider it evidence of a personality disorder. When clinicians assess for the presence of a personality disorder, one important requirement is that the pattern be consistent across a wide variety of settings, situations, and relationships. If Edwards was so susceptible to the power of authority figures that he submitted a false handwritten confession, pled guilty against his will, and made an apology in open court, there would have to be concrete evidence of similar behaviors in other contexts, such as making poor life decisions based on pressure from family members, friends, or significant others, or grossly disadvantageous decisions at work. No such evidence is provided other than testimony by his father and girlfriend that he had difficulty standing up for himself. On the contrary, according to information provided by the prosecuting attorney, Edwards pled guilty against the advice of both his father and girlfriend, raising further questions about whether Edwards' poor decision regarding his guilty plea was related to an underlying personality disorder.
The application of the term "Cluster C Personality Disorder" in describing Edwards' tendencies to be submissive raises its own questions. Cluster C contains avoidant, dependent, and obsessive-compulsive personality disorders. The traits noted in the case seem to most closely conform to dependent personality disorder, which includes the following criterion: "has difficulty expressing disagreement with others because of fear of loss of support or approval." Did Mr. Edwards' behavior really fit the DSM-IV criteria of the disorder? The complete definition of dependent personality disorder makes clear that individuals with the disorder have a "pervasive and excessive need to be taken care of that leads to submissive and clinging behavior and fears of separation." (DSM-IV, p. 668). It would therefore only make sense to apply this diagnosis if it could be established that the motivation for Edwards' behavior was to please his attorney. If, on this occasion, he was bullied into pleading guilty, the underlying dynamics of such submission would not be part of the criteria for any personality disorder.
