CALVIN SLEDGE, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Calvin Sledge appeals his convictions for battery on a law enforcement officer and resisting an officer without violence. The appellate court reversed and remanded because the trial court failed to conduct a formal competency hearing before proceeding to trial, despite prior findings of incompetency and a letter indicating potential competency.
A trial court cannot proceed to trial without a formal hearing to determine competency once a defendant has been adjudicated incompetent. The legal status of a defendant cannot be changed from incompetent to competent without a judicial hearing and determination.
[1] A trial court has an independent duty to grant a competency hearing when there is evidence that a defendant may be incompetent to stand trial.
[2] Conflicting expert opinions regarding a defendant's competency to stand trial necessitate a hearing to resolve the discrepancies.
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Join FLexlaw to unlock all legal intelligence“the legal status of a defendant cannot be adjudicated from incompetent to competent without a hearing”
Establishes the core requirement that a formal hearing is mandatory to change a defendant's competency status
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Join FLexlaw to unlock all legal intelligenceSledge was charged with various crimes and adjudicated incompetent to proceed to trial on September 12, 2001. He was found incompetent again on March …
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SAWAYA, C.J.
Calvin Sledge appeals his judgments and sentences for battery on a law enforcement officer and resisting an officer without violence. We reverse and remand for a hearing to determine whether Sledge is competent to proceed to trial.
On September 12, 2001, after the State filed its information charging him with various crimes, Sledge was adjudicated incompetent to proceed to trial and committed to the Department of Children and Families (DCF) for hospitalization. The record reveals that Sledge was again found incompetent on March 4, 2002.
On April 12, 2002, following Sledge’s most recent clinical evaluation, DCF wrote a letter stating that Sledge was competent to proceed. Rather than conducting a formal hearing to determine whether Sledge was competent, the trial judge simply set a trial date and proceeded to trial. The jury returned verdicts of guilty, and Sledge was sentenced to a term of incarceration as a prison releasee reoffender. Florida Rule of Criminal Procedure 3.210(a) provides that “[a] person accused of an offense ... who is mentally incompetent to proceed at any material stage of a criminal proceeding shall not be proceeded against while incompetent.” Moreover, once adjudicated incompetent, “the legal status of a defendant cannot be adjudicated from incompetent to competent without a hearing.” Alexander v. State, 380 So. 2d 1188, 1190 (Fla. 5th DCA 1980); see also Samson v. State, 853 So. 2d 1116 (Fla. 4th DCA 2003). Therefore, once a defendant is found incompetent to stand trial, there must be a “subsequent finding that he ha[s] regained his competency in order to proceed.” Blue v. State, 837 So. 2d 541, 543 (Fla. 4th DCA 2003) (reversing and remanding for a new trial after a competency hearing is held and the defendant adjudged competent to proceed to trial); see also Jackson v. State, 810 So. 2d 545 (Fla. 4th DCA 2002) (holding that a judicial determination of incompetence remains valid until there is a subsequent judicial determination that the defendant is competent to proceed); Downing v. State, 617 So. 2d 864 (Fla. 1st DCA 1993) (remanding with instructions that the petitioner receive a hearing on continued incompetency).
We note, parenthetically, that the State properly concedes that the trial court should have determined whether Sledge was competent before proceeding with the trial. Therefore, we reverse Sledge’s convictions and sentences and remand for a competency hearing and a new trial should Sledge be found competent to proceed.
REVERSED AND REMANDED.
PALMER and MONACO, JJ., concur.
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Citator
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Molina v. State, 946 So. 2d 1103 (Fla. 5th DCA 2006)…Once found incompetent, a presumption clings to the criminal defendant that the state of incompetence persists until a court, after proper notice and a hearing, finds otherwise. Jackson v. State, 880 So. 2d 1241 (Fla. 1st DCA 2004); Sledge v. State, 871 So. 2d 1020 (Fla. 5th DCA 2004). The procedure for subsequent hearings to determine whether competency has been restored is found in rule 3.212, Florida Rules of Criminal Procedure, which requires that within thirty days of receipt of a report from the administ…
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Rumph v. State, 217 So. 3d 1092 (Fla. 5th DCA 2017)…ompetency arises that persists until the trial court adjudicates the defendant competent to proceed. Molina v. State, 946 So. 2d 1103 (Fla. 5th DCA 2006) (citing Jackson v. State, 880 So. 2d 1241, 1242 (Fla. 1st DCA 2004)); see also Sledge v. State, 871 So. 2d 1020 (Fla. 5th DCA 2004). “[T]he failure to obsei-ve procedures adequate to protect'a defendant’s right not to be tried or convicted while incompetent to stand trial deprives him of his due process right to a fair trial.” Drope [*1095] v. Missouri. 420 U…
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Cornell Jackson v. State, 880 So. 2d 1241 (Fla. 1st DCA 2004)…ed that, although the supreme court has held that, where the parties and the trial court agree, the court may decide the issue of competency on the basis of the written reports, there was no such agreement in the case. Id.; see also Sledge v. State, 871 So. 2d 1020, 1021 (Fla. 5th DCA 2004) (reversing for a competen [*1243] cy hearing because the trial ■ court, upon receipt of the Department of Children and Families’ clinical evaluation stating that the appellant was competent to testify, simply set a date for…
Previewing 3 of 10 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Elizar Samson v. State, 853 So. 2d 1116 (Fla. 4th DCA 2003)
- Keydrum Blue v. State, 837 So. 2d 541 (Fla. 4th DCA 2003)
- Alexander v. State, 380 So. 2d 1188 (Fla. 5th DCA 1980)
- Jackson v. State, 810 So. 2d 545 (Fla. 4th DCA 2002)
- Downing v. State, 617 So. 2d 864 (Fla. 1st DCA 1993)