LAWRENCE JOHN KENDALL, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Affirmed conviction despite admission of prior competency finding in insanity trial, holding that while the standards differ, any error was harmless given other evidence explaining the distinctions and expert testimony on sanity.
Although evidence of a prior judicial finding of competency to stand trial should ordinarily not be admitted in an insanity trial, any error in its admission was harmless where other evidence explained the differences between competency and insanity standards and the jury heard lay and expert testimony on sanity.
[1] Evidence of a prior judicial finding of competency to stand trial in another case should ordinarily not be admitted in an insanity trial, as the standards for competency…
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Join FLexlaw to unlock all legal intelligenceAppellant Kendall was tried and convicted, with evidence of a prior judicial finding of competency to stand trial from another case admitted at trial.…
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PER CURIAM.
Affirmed. Although we agree with appellant that the standards for determining competency to stand trial and for determining insanity are substantially different and that ordinarily evidence of a prior judicial finding of competency to stand trial in another case should not be admitted, we do not believe that harmful error has been demonstrated in this case by the admission of such evidence. While we believe that the judicial finding should not have been admitted, we do not agree that evidence of competency to stand trial is totally irrelevant to the issue of sanity presented to the jury. We also believe that appellant’s contention on appeal of prejudicial error is undermined by his failure to request an instruction delineating the difference between the concept of insanity as a defense and the concept of competency to stand trial, or to object to the instructions on the insanity defense which he now claims exacerbated the error in receiving the evidence of competency to stand trial.
More importantly, however, we believe that any error in admitting such evidence was rendered harmless by other evidence presented to the jury which explained the differences between the two concepts and the standards utilized to determine their existence. In addition the jury was presented with both lay and expert testimony on the issue of appellant’s sanity.
ANSTEAD, C.J., and LETTS and GLICKSTEIN, JJ., concur.
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Laster v. Sec'y, Dep't of Corrections(Polk County) (M.D. Fla. 2025)…sby, 462 F.2d 1201, 1203 (D.C. Cir. 1972) (“The competency of a defendant to stand trial is, of course, crucial to fairness, and is gauged by a somewhat stricter standard than is the competency of a witness to testify."). See also, Kendall v. State, 448 So. 2d 1258, 1258 (Fla. 4th DCA 1984) ("[O]rdinarily evidence of a prior judicial finding of competency to stand trial in another case should not be admitted...."); Fla. Stat., § 916.12 (“A defendant is incompetent to proceed within the meaning of this chapter…