SYLVESTER HAYES, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Florida appellate court reversed a probation revocation when the trial judge refused to hold a competency hearing despite counsel's motion. The court held that competency hearings must be available in probation revocation proceedings because such proceedings are criminal proceedings where a defendant's liberty is at stake.
A trial court has the authority and obligation to hold a competency hearing in probation revocation proceedings if facts raise doubt about a defendant's mental competence. Probation revocation hearings are criminal proceedings within the scope of competency rules because the defendant's liberty is at stake and his ability to assist in his own defense may be determinative of the revocation outcome.
[1] A trial court must hold a competency hearing if facts brought to its attention raise a doubt as to the defendant's sanity during criminal proceedings.
[2] A probation revocation hearing is a criminal proceeding for the purpose of determining a defendant's mental competency.
Previewing 2 of 4 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“if at any time while criminal proceedings are pending against a person accused of crime, whether before or during or after the trial, the trial court . has facts brought to its attention which raise a doubt of the sanity of the Defendant, the question should be settled before further steps are taken.”
Establishes the common-law rule in Florida that competency must be addressed in any criminal proceeding when sanity is in doubt
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Join FLexlaw to unlock all legal intelligenceAppellant was charged with aggravated assault while on probation for a prior offense. During the probation revocation hearing, appellant's counsel mov…
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PER CURIAM.
Appellant was charged with aggravated assault while on probation for a prior criminal offense. A probation revocation hearing was held to determine whether the alleged assault constituted a violation of appellant’s probation. During the hearing, appellant’s counsel moved that a hearing be held to determine appellant’s mental competence to stand trial. The court granted the motion for a hearing as to the pending substantive charge, but denied it as to the probation revocation proceedings. Appellant’s probation was revoked, and he was sentenced to five years in prison. Appellant appeals the order revoking his probation. We reverse.
It appears from the record that the trial judge was under the impression that there was no authority for him to conduct a competency hearing in a probation revocation proceeding. The common-law rule which has long been recognized in Florida is that “if at any time while criminal proceedings are pending against a person accused of crime, whether before or during or after the trial, the trial court . has facts brought to its attention which raise a doubt of the sanity of the Defendant, the question should be settled before further steps are taken.” Brown v. State, 245 So. 2d 68, 70 (Fla.1971) (emphasis added).
Fla.R.Crim.P. 3.210(a) provides for a hearing to determine a defendant’s competency at the time of trial if there are reasonable grounds to believe the defendant is insane. The purpose of the common-law rule and the rule of procedure is to insure that all persons who must defend themselves in the criminal arena are mentally capable of assisting in the conduct of that defense. See Deeb v. State, 118 Fla. 88,158 So. 880 (1935).
A probation revocation hearing is, therefore, a criminal proceeding within the purview of the rules, since the defendant’s liberty is at stake and his ability to assist in his own defense may be determinative of the outcome of the revocation hearing.
The order revoking appellant’s probation is vacated. The case is remanded for a hearing to determine appellant’s present competence and for further proceedings consistent with this opinion.
BOARDMAN, C. J., and McNULTY and OTT, JJ., concur.
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Thompson v. Crawford, 479 So. 2d 169 (Fla. 3d DCA 1985)…Procedure 3.210(a) — that a person is not to be proceeded against while incompetent — “is to insure that all persons who must defend themselves in the criminal arena are mentally capable of assisting in the conduct of that defense.” Hayes v. State, 343 So. 2d 672, 673 (Fla. 2d DCA 1977). This rule protects the accused’s due process right to a fair trial, see Drope v. Missouri, 420 U.S. 162, 95 S.Ct. 896, 43 L.Ed.2d 103 (1975); Scott v. State, 420 So. 2d 595 (Fla.1982); see also Weber v. State, 438 So. 2d 982…
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Pericola v. State, 499 So. 2d 864 (Fla. 1st DCA 1986)…trial is not mentioned. Further, the purpose of determining competency to stand trial is “to insure that all persons who must defend themselves in the criminal arena are mentally capable of assisting in the conduct of that defense.” Hayes v. State, 343 So. 2d 672, 673 (Fla.2d DCA 1977). At the sentencing phase, a defendant has been found guilty; no further defense “in the criminal arena” need be conducted. Finally, this court’s decision in Baranko v. State, 428 So. 2d 324 (Fla. 1st DCA 1983) does not mandate…
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Schofield v. Grady C. Judd, 268 So. 3d 890 (Fla. 2d DCA 2019)
Authorities Cited
- Brown v. State, 245 So. 2d 68 (Fla. 1971)
- Deeb v. State, 118 Fla. 88 (Fla. 1935)