JEFFREY L. BOGGS, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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The Florida appellate court reversed Boggs' conviction and sentence because the trial court erred in denying his motion for a sanity inquisition (competency evaluation) despite evidence raising reasonable grounds to question his mental competence to stand trial. The court held that once reasonable grounds for incompetency are presented, the trial court must order an examination rather than make its own determination of competency.
Once a court is presented with reasonable grounds to believe a defendant is not mentally competent to stand trial, the court is obligated to grant a proper motion for a sanity inquisition. The trial court cannot weigh evidence and deny the examination based on its own conclusion that the defendant is competent; the proper process requires ordering the examination when reasonable grounds exist, even if other evidence suggests competency.
[1] A court is obligated to grant a motion for a sanity inquisition when presented with reasonable grounds to believe that a defendant is not mentally competent to stand tria…
[2] A court's obligation to order a sanity inquisition is triggered by reasonable grounds to believe a defendant may be incompetent, not by the court's own determination of i…
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Join FLexlaw to unlock all legal intelligence“once a court is presented with "reasonable grounds to believe" that a defendant before the court is not mentally competent to stand trial or be sentenced, the court is obligated to grant a proper motion for a sanity inquisition”
States the binding legal rule that trial courts must order competency examinations upon presentation of reasonable grounds
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Join FLexlaw to unlock all legal intelligenceBoggs was charged with two burglaries and faced probation revocation proceedings on two prior burglary convictions. The Pinellas County Commission Con…
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OTT, Acting Chief Judge.
After a rather protracted history of criminal and mental aberration, appellant was charged with the commission of two burglaries, which also triggered proceedings to revoke his probation on two previous burglary convictions. Appellant filed sanity inquisition motions in all the proceedings. We find error in the lower court’s denial of this sanity inquisition.
The Pinellas County Commission Consulting Psychiatrist to the County Jail notified the public defender that he had examined the appellant and found he did not have sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding, nor to have a rational and factual understanding of the proceedings against him. Thereupon the public defender moved the circuit court, under Fla.R. Crim.P. 3.210(a)(2), to appoint experts to examine and report on appellant’s competency to stand trial. Copies of reports detailing appellant’s mental history back to 1973, including the consultant psychiatrist’s report after his latest arrest, were appended to the motion. The motion was denied, whereupon appellant entered a plea of nolo contendere, reserving his right to prosecute this appeal from the denial of his motion. Appellant was sentenced to two concurrent five year terms on the earlier convictions and two additional and consecutive five year terms.
We think the circuit judge had no alternative but to order the requested inquisition. As we understand Rule 3.210, once a court is presented with “reasonable grounds to believe” that a defendant before the court is not mentally competent to stand trial or be sentenced, the court is obligated to grant a proper motion for a sanity inquisition. Bolius v. State, 319 So. 2d 85 (Fla. 2d DCA 1975). The rule does not require the court to order an examination only if the court “reasonably believes” that the defendant is not mentally competent.
In other words, the process is not one in which the court weighs whatever evidence is before it and then orders the examination only if it is persuaded that the defendant in fact is mentally incompetent. To our minds it would be anomalous to require the court to reach such a conclusion without the benefit of the very evidence sought by the motion.
While it is true that in the case at bench there was evidence from which the circuit judge could reasonably conclude that appellant was not insane at the time of trial, within the McNaughton definition, still the positive unequivocal opinion of the consultant psychiatrist constituted reasonable grounds for believing that appellant might not be mentally competent to stand trial and thus the motion could not be denied.
The judgments and sentences of the circuit court are reversed and the case remanded for a full hearing to determine appellant’s mental competence to stand trial, and thereafter such further proceedings as may be necessary or appropriate.
RYDER and DANAHY, JJ., concur.
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Walker v. State, 384 So. 2d 730 (Fla. 4th DCA 1980)…te, 262 So. 2d 737 (Fla. 2d DCA 1972), on remand 271 So. 2d 201 (Fla. 2d DCA 1973); Mitchell v. State, 289 So. 2d 418 (Fla. 2d DCA 1974), on remand 311 So. 2d 181 (Fla. 2d DCA 1975); Meeks v. State, 289 So. 2d 479 (Fla. 3d DCA 1974); Boggs v. State, 375 So. 2d 604 (Fla. 2d DCA 1979). Support for this position can also be found in Federal decisions dealing with the constitutional right not to be tried while incompetent and with the Federal rule dealing with mental competency to stand trial. 18 U.S.C.A., Secti…
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Kothman v. State, 442 So. 2d 357 (Fla. 1st DCA 1983)…ant may be incompetent, not whether he is incompetent,” Scott v. State, 420 So. 2d 595 (Fla.1982) citing Walker v. State, 384 So. 2d 730 (Fla. 4th DCA 1980) (emphasis in original); Walker v. State, 428 So. 2d 321 (Fla. 1st DCA 1983); Boggs v. State, 375 So. 2d 604 (Fla. 2d DCA 1979). Once the judge is presented with reasonable grounds to believe a defendant may not have sufficient present ability to consult with his attorney and aid in the preparation of his defense with a reasonable degree of understanding,…
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W.S.L. v. State, 470 So. 2d 828 (Fla. 2d DCA 1985)…ct. We believe the psychologist’s report provided reasonable grounds for a belief that defendant at least may have been incompetent. Under these circumstances the rule required a hearing on defendant’s competency to stand trial. Cf. Boggs v. State, 375 So. 2d 604 (Fla. 2d DCA 1979) (holding that under Florida Rule of Criminal Procedure 3.210 a hearing to determine defendant’s competency to stand trial is required if there are reasonable grounds to believe defendant is incompetent, regardless of whether or no…
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Bolius v. State, 319 So. 2d 85 (Fla. 2d DCA 1975)