PHILLIPS
v.
STATE OF FLORIDA
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Appellant challenged the trial court's refusal to hold a competency hearing and enter a competency finding. The appellate court affirmed, finding that nothing in the record provided reasonable grounds to believe Appellant was mentally incompetent to proceed.
The trial court did not commit fundamental error. The record contained no reasonable grounds to believe the appellant was mentally incompetent to proceed, and therefore the trial court was not required to hold a competency hearing or enter a competency finding.
“nothing in defense counsel's motion for competency evaluation, the trial court's order authorizing the evaluation, or the record as a whole provided reasonable grounds to believe Appellant was not mentally competent to proceed”
Establishes the legal standard for when a competency hearing is required—there must be reasonable grounds to question competency based on the record
The appellant requested a competency evaluation, and the trial court authorized such evaluation. However, the trial court did not hold a formal compet…
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FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
No. 1D2024-0993
WAYNE L. PHILLIPS,
Appellant,
v. STATE OF FLORIDA,
Appellee.
On appeal from the Circuit Court for Taylor County. Gregory Stuart Parker, Judge.
May 21, 2025
PER CURIAM.
We reject Appellant’s argument that the trial court fundamentally erred by not holding a competency hearing and entering a finding of competency. See Awolowo v. State, 389 So. 3d 788 (Fla. 1st DCA 2024), review granted, No. SC2024-1165, 2024 WL 5241703 (Fla. Dec. 27, 2024). Here, as in Awolowo, nothing in defense counsel’s motion for competency evaluation, the trial court’s order authorizing the evaluation, or the record as a whole provided reasonable grounds to believe Appellant was not mentally competent to proceed.
AFFIRMED.
2
OSTERHAUS, C.J., and LEWIS and ROBERTS, JJ., concur.