JAMES WILLIAMS
v.
STATE OF FLORIDA

Fla. 5th DCA | 2022-07-22
No. 22-0103
Florida District Court of Appeal, Fifth District (2022) Positive Treatment
Cited by 1 case

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Holding

When the State confesses error regarding defendant's trial competency, the case must be reversed and remanded for a competency hearing and nunc pro tunc determination of competency.


Headnotes

[1] When the State confesses error regarding a defendant's competency to stand trial, a trial court must conduct a competency hearing and, if possible, make a nunc pro tunc d…

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Facts & Procedural History

James Williams was convicted in the Circuit Court for Sumter County. The State subsequently confessed error concerning whether Williams was competent …

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Opinion of the Court

PER CURIAM.

Based upon the State’s proper confession of error, we reverse and remand for a competency hearing and a nunc pro tunc determination, if possible, as to whether Appellant was competent to proceed to trial. See 254 So. 3d 1131, 1132 (Fla. 5th DCA 2018). If the court finds that Appellant was competent at the time of trial, it must enter a nunc pro tunc order memorializing that finding with no change in the judgment or sentence. Yancy, 280 So. 3d at 1113. If a retroactive determination is not possible, or if the court finds that Appellant was incompetent, Appellant will be entitled to a new trial if and when competent to proceed. Id. at 1113–14. REVERSED and REMANDED with Instructions.

WALLIS, HARRIS AND SASSO, JJ., concur.


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Citator

Cited By

  • Ellis v. State (Fla. 1st DCA 2021)
    …appellate courts consistently reverse competency findings when it is not clear from the record whether the trial court read the expert reports before accepting a stipulation of a defendant’s competency based on those reports.”); Yancy v. State, 280 So. 3d 1112, 1113 (Fla. 5th DCA 2019) (remanding for a nunc pro tunc competency determination because it was unclear from the record whether the trial court read the expert’s evaluation and made an independent determination). 7 Even so, Ellis argues t…

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