NICHOLAS RAY MALICOAT
v.
THE STATE OF FLORIDA

Fla. 3d DCA | 2023-08-02
No. 22-0952
Florida District Court of Appeal, Third District (2023)

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Holding

A trial court has no obligation to hold a competency hearing when the defendant does not request one and presents no evidence suggesting the defendant may lack competency to stand trial.


Headnotes

[1] A trial court has no obligation to conduct a competency hearing absent a request from defense counsel or a showing that the defendant may lack competency to stand trial.

[2] Mental illness, low intelligence, bizarre behavior, or volatile and irrational conduct alone do not establish incompetence to stand trial; incompetence requires evidence…

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Key Quotes

“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.”

From Byron v. State, quoted to establish the standard for competency to stand trial

Facts & Procedural History

Nicholas Ray Malicoat appealed a conviction from Monroe County Circuit Court. The defendant did not request a competency examination or make any showi…

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Opinion of the Court

PER CURIAM.

Affirmed. Byron v. State, 273 So. 3d 1091, 1094 (Fla. 3d DCA 2019) (quoting Thompson v. State, 88 So. 3d 312, 319 (Fla. 4th DCA 2012)) (“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. Neither low intelligence, mental deficiency, nor bizarre, volatile, and irrational behavior can be equated with mental incompetence to stand trial.”); Cotton v. State, 177 So. 3d 666, 668 (Fla. 1st DCA 2015) (“If the trial court does not have sufficient grounds to believe that the defendant may lack competency, there is no obligation to hold a competency hearing.”); Andrews v. State, 916 So. 2d 964, 966 (Fla. 5th DCA 2005) (“Defense counsel never asked for a competency exam, so, we must assume that counsel believed [defendant] to be competent.”); Chery v. State, 642 So. 2d 1161, 1162 (Fla. 3d DCA 1994) (“The trial court did not err in failing to conduct an inquiry concerning the defendant’s mental competency to stand trial as no showing of mental incompetency was ever made below, and no defense request for such an inquiry was ever made below.”).

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