The People of the State of Colorado, Petitioner/cross-Respondent v. Rashaim Malique Davis, Respondent/cross-Petitioner

Summary

The court held that Colorado's existing two-part framework for waiver of counsel adequately permits trial courts to consider a mentally ill defendant's competence and the voluntariness, knowingness, and intelligence of the waiver, so no additional competency standard was required. It also held that the possession conviction had to merge into the distribution conviction because the evidence did not establish beyond a reasonable doubt that the convictions involved different quantities of drugs. The court therefore reversed the court of appeals on both issues and remanded for the possession conviction and sentence to be vacated.