DELFIN QUESADA, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Delfin Quesada appealed the denial of his Rule 3.850 motion for post-conviction relief, arguing that the trial court failed to hold a competency hearing before accepting his guilty plea and that he received ineffective assistance of counsel. The appellate court affirmed the trial court's denial, finding no reasonable doubt as to Quesada's sanity and no mockery or farce in his trial proceedings.
The trial court properly denied post-conviction relief because no reasonable doubt was raised as to Quesada's sanity—all three psychiatric experts concluded he was sane—making a competency hearing unnecessary. Additionally, Quesada failed to demonstrate that his trial was a mockery or farce, the test for ineffective assistance of counsel.
[1] A hearing to determine a defendant's sanity is obligatory if a reasonable doubt is raised as to the defendant's sanity.
[2] A trial court is not required to hold a sanity hearing if psychiatric reports conclude the defendant is sane and the court has no reasonable grounds to believe otherwise.
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“a hearing to determine a defendant's sanity is obligatory if a reasonable doubt is raised as to the defendant's sanity”
Establishes the legal rule for when competency hearings are required in Florida before accepting guilty pleas
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceQuesada was charged in 1970 with buying, receiving and concealing stolen property, and in 1971 with breaking and entering and grand larceny. He announ…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Insanity Defense cases and more on FLexlaw
PER CURIAM.
This is an appeal by the defendant, Del-fin Quesada, from an order of the trial court summarily denying a motion for post-conviction relief pursuant to Rule 3.850 RCrP. Quesada was charged by information in 1970, with buying, receiving and concealing stolen property, and in 1971, with breaking and entering and grand larceny. Represented by the public defender, Quesada pled not guilty to the charges and advised the court that he would interpose insanity as a defense. Subsequently he was again charged by information with breaking and entering, to which he pled not guilty.
Prior to trial, Quesada was examined by three psychiatrists. In the reports, the doctors acknowledge his emotional problems, but state that he was able to aid counsel in the preparation of his defense and stand trial, and that he knew the difference between right and wrong at the time of the alleged offenses. At the time of trial, Quesada, represented by private counsel, changed his plea to guilty on all charges except one which the State agreed to abandon. On March 10, 1972, Quesada was sentenced to S years in the state penitentiary for buying, receiving and concealing stolen property, 10 years for breaking and entering and 5 years for grand larceny.
On October 1, 1974, Quesada filed a motion to vacate pursuant to Rule 3.850, RCrP., on two grounds. First, that no hearing was held on the issue of the defendant’s competence prior to the acceptance of his guilty plea. Second, that Que-sada did not receive effective assistance of counsel since the only defense he received from his attorney was pleading guilty when he should have pled not guilty by reason of insanity. On November 20, 1974, the trial judge denied the Rule 3.850 motion without an evidentiary hearing.
Quesada’s arguments on appeal are not well taken. As to whether the trial court should have granted post conviction relief based upon failure to hold a hearing on Quesada’s competence prior to accepting the guilty plea, we agree that the rule espoused by the Florida Supreme Court is that a hearing to determine a defendant’s sanity is obligatory if a reasonable doubt is raised as to the defendant’s sanity. Brock v. State, Fla. 1954, 69 So. 2d 344; Brown v. State, Fla.1971, 245 So. 2d 68. Under the facts of this case, the rule is inapplicable since no doubt was raised as to the defendant’s sanity. The written reports of all three psychiatric experts concluded that Quesada was sane, and the court had no reasonable grounds to believe him insane. See Rule 3.210(a), RCrP. As to whether a defendant has received reasonably effective counsel, the test is whether the facts alleged demonstrate that the trial was a mockery or a farce. McCrae v. State, Fla.App.1975, 313 So. 2d 429. The record does not support such a finding. Accordingly, the order of the trial court is affirmed.
Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Glimmert Beckham v. State, 339 So. 2d 221 (Fla. 3d DCA 1976)…. To successfully collaterally attack a judgment on the grounds of ineffective assistance of counsel, the facts alleged must demonstrate that the trial was a mockery or a farce. Simpson v. State, 164 So. 2d 224 (Fla. 3d DCA 1964); Quesada v. State, 321 So. 2d 442 (Fla. 3d DCA 1975). Further, mishandling of a trial with regards to matters falling within the judgment or strategy of counsel does not constitute ineffective assistance of counsel. Solloa v. State, 221 So. 2d 217 (Fla. 3d DCA 1969). At most Beckh…
-
Robinson v. State, 378 So. 2d 1346 (Fla. 3d DCA 1980)…To prevail on a motion to vacate judgment and sentence on the ground of ineffective assistance of counsel, a defendant must demonstrate that his trial was a mockery or a farce. Simpson v. State, 164 So. 2d 224 (Fla. 3d DCA 1964); Quesada v. State, 321 So. 2d 442 (Fla. 3d DCA 1975). Further, mishandling of a trial with regard to matters falling within the judgment or strategy of counsel does not constitute ineffective assistance of counsel. Solloa v. State, 227 So. 2d 217 (Fla. 3d DCA 1969). After a perusal…
-
Arbogast v. State, 340 So. 2d 1179 (Fla. 3d DCA 1976)…Lebowitz v. State, 313 So. 2d 473 (Fla.3d DCA 1975); Williams v. State, 320 So. 2d 434 (Fla.3d DCA 1975). Defendant has failed to demonstrate fundamental error and further has not shown that his trial was a mockery or a farce. See Quesada v. State, 321 So. 2d 442 (Fla.3d DCA 1975). Accordingly, we affirm the denial of his motion for post-judgment relief. Defendant also filed a motion to vacate sentence on the ground that the trial court incorrectly sentenced him to serve one year in the state penitentiary o…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Brown v. State, 245 So. 2d 68 (Fla. 1971)
- Brock v. State, 69 So. 2d 344 (Fla. 1954)
- McCRAE v. State, 313 So. 2d 429 (Fla. 3d DCA 1975)