LUKER
v.
STATE OF FLORIDA
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When an expert evaluation concludes a defendant is competent to stand trial and nothing in the motion or record provides reasonable grounds to doubt competency, the trial court does not commit fundamental error by failing to hold a competency hearing or enter a written competency order.
[1] When an expert evaluation concludes a defendant is competent to stand trial and the record contains no reasonable grounds to doubt competency, a trial court does not comm…
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Join FLexlaw to unlock all legal intelligenceLuker was convicted of first-degree murder. After Luker moved for a competency evaluation, the trial court appointed an expert who concluded Luker was…
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FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
AUBREY JAMES LUKER, Appellant,
V.
STATE OF FLORIDA, Appellee.
No. 1D2025-0099
On appeal from the Circuit Court for Santa Rosa County. Clifton Alan Drake, Judge.
June 3, 2026
PER CURIAM.
Aubrey Luker appeals his judgment and sentence for firstdegree murder, challenging the denial of his motion for judgment of acquittal, the admission of photographs depicting him in jail attire and handcuffs, and the trial court's failure to hold a competency hearing or enter a written order adjudicating Luker competent. We affirm and write only to address the competency issue.
After Luker moved for a competency evaluation, the trial court appointed an expert who concluded that Luker was competent to stand trial. Thereafter, the trial court neither held a competency hearing nor entered a written competency order. Because nothing in Luker's motion or the record provided
"reasonable grounds" to doubt Luker's competency to proceed, the trial court did not commit fundamental error. Hicks v. State, 391 So. 3d 620, 624 (Fla. 1st DCA 2024), review granted sub nom. Hicks v. Florida, No. SC2024-1182, 2025 WL 2622056 (Fla. Sept. 11, 2025); accord Davis v. State, 394 So. 3d 801, 804 (Fla. 1st DCA 2024); Awolowo v. State, 389 So. 3d 788, 798 (Fla. 1st DCA 2024).
AFFIRMED.
RAY, WINOKUR, and TREADWELL, JJ., concur.
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Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Luker v. State (Fla. 1st DCA 2026)