MARK ANTHONY JACKSON
v.
STATE OF FLORIDA

Fla. 4th DCA | 2026-05-13
No. 2025-1359
Linn, J., Levine, J., Conner, J., Shepherd, J.
2026 FL 5659 Florida District Court of Appeal, Fourth District (2026) Positive Treatment
Cited by 2 cases

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Holding

A presumption of competence attaches to a defendant from a previous determination of competency to stand trial and applies in later proceedings.


Headnotes

[1] Once a defendant is determined competent to stand trial, a presumption of competence attaches to the defendant in later proceedings.

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Key Quotes

“A presumption of competence attaches from a previous determination of competency to stand trial.”

Wall v. State, 326 So. 3d 1065, 1069-70 (Fla. 2021)

Facts & Procedural History

Mark Anthony Jackson appealed a judgment from the Circuit Court for the Nineteenth Judicial Circuit, St. Lucie County.…

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Opinion of the Court

DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA

FOURTH DISTRICT

MARK ANTHONY JACKSON, Appellant,

V.

STATE OF FLORIDA, Appellee.

No. 4D2025-1359

[May 13, 2026]

Appeal from the Circuit Court for the Nineteenth Judicial Circuit, St. Lucie County; Michael James Linn, Judge; L.T. Case No. 562023CF000779AXXXXX.

Daniel Eisinger, Public Defender, and Siobhan Shea, Assistant Public Defender, West Palm Beach, for appellant.

James Uthmeier, Attorney General, Tallahassee, and Marcus Russell Kelly II, Assistant Attorney General, West Palm Beach, for appellee.

PER CURIAM.

Affirmed. Wall v. State, 326 So. 3d 1065, 1069-70 (Fla. 2021) (“[A] presumption of competence attaches from a previous determination of competency to stand trial.” (first quoting Hunter v. State, 660 So. 2d 244, 248 (Fla. 1995); and then citing Durocher v. Singletary, 623 So. 2d 482, 484 (Fla. 1993))); Boyd v. State, 910 So. 2d 167, 187 (Fla. 2005) (“Once a defendant is determined competent to stand trial, a presumption of competence attaches to the defendant in later proceedings." (citing Durocher, 623 So. 2d at 484)).

LEVINE, CONNER and SHEPHERD, JJ., concur.

* * *

Not final until disposition of timely-filed motion for rehearing.


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