CALVIN ESSIX
v.
THE STATE OF FLORIDA
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Calvin Essix appealed his convictions in two cases, challenging the trial court's determination that he was competent to stand trial despite evidence of mental illness. The appellate court affirmed, holding that mental illness alone does not establish incompetence without a showing of present inability to assist counsel or understand charges.
The court affirmed the trial court's competency determination, holding that not every manifestation of mental illness demonstrates incompetence to stand trial. Rather, competence requires evidence of a present inability to assist counsel or understand the charges, and low intelligence, mental deficiency, or bizarre behavior alone cannot establish incompetence.
“Not every manifestation of mental illness demonstrates incompetence to stand trial; rather, the evidence must indicate a present inability to assist counsel or understand the charges.”
Establishes the legal standard for competency to stand trial—mental illness alone is insufficient
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Join FLexlaw to unlock all legal intelligenceEssix was tried in two separate cases (Lower Tribunal Nos. F04-31438 and F05-37175) in Miami-Dade County Circuit Court. The trial court, presided over…
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Third District Court of Appeal State of Florida
Opinion filed January 2, 2025. Not final until disposition of timely filed motion for rehearing.
________________
Nos. 3D22-1841 & 3D22-1842 Lower Tribunal Nos. F04-31438 & F05-37175 ________________
Calvin Essix, Appellant,
vs.
The State of Florida, Appellee.
Appeals from the Circuit Court for Miami-Dade County, Ramiro C. Areces, Judge.
Wasson & Associates, Chartered, and Roy D. Wasson, for appellant.
Ashley Moody, Attorney General, and Linda Katz, Assistant Attorney General, for appellee.
Before LOGUE, C.J., and GORDO and LOBREE, JJ.
PER CURIAM.
Affirmed. Byron v. State, 273 So. 3d 1091, 1094 (Fla. 3d DCA 2019) (“Not every manifestation of mental illness demonstrates incompetence to
2 stand trial; rather, the evidence must indicate a present inability to assist counsel or understand the charges. Neither low intelligence, mental deficiency, nor bizarre, volatile, and irrational behavior can be equated with mental incompetence to stand trial.” (quoting Thompson v. State, 88 So. 3d 312, 319 (Fla. 4th DCA 2012))); Pickles v. State, 976 So. 2d 690, 692 (Fla. 4th DCA 2008) (“We review determinations of the trial court not to hold a competency hearing under an abuse of discretion standard.”).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Pickles v. State, 976 So. 2d 690 (Fla. 4th DCA 2008)
- Byron v. State, 273 So. 3d 1091 (Fla. 3d DCA 2019)