Albert Holland was convicted in Florida of murdering a police officer and sentenced to death after a trial at which the court repeatedly denied his requests to represent himself. Holland had a substantial history of brain injury, schizophrenia diagnoses, hospitalization, paranoia, and an insanity defense, and the Florida Supreme Court upheld the denial of self-representation. The federal district court granted habeas relief on the ground that the denial violated Faretta, but the Eleventh Circuit held that the state court reasonably determined that Holland’s mental condition prevented a knowing and voluntary waiver of counsel. The court also held that Indiana v. Edwards supplied an alternative basis for denying relief because it permits a state to require counsel when a defendant lacks the mental capacity to conduct a trial, even if he is competent to stand trial. Applying AEDPA and Brecht, the court rejected Holland’s challenges to an inaudible videotape and improper expert opinion because neither had a substantial and injurious effect on the verdict. It further rejected his ineffective-assistance claims concerning the prosecutor’s closing argument, concluding that the Florida courts reasonably found no deficient performance or prejudice, and rejected his Miranda claim because Holland—not the detective—initiated the later questioning after requesting counsel. The Eleventh Circuit reversed the grant of habeas relief, affirmed the denial of relief on the other claims, and remanded with instructions to reinstate the conviction and sentence.