BENJAMIN COKER, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Benjamin Coker challenged the denial of his postconviction motion alleging fundamental error and ineffective assistance of counsel for the failure to hold a competency hearing before his guilty plea. The court affirmed the fundamental error claim but reversed on the ineffective assistance claim, finding that counsel's deficient performance in failing to secure a written competency order, combined with prejudicial impact from evidence of incompetence, warranted relief.
Counsel's performance was deficient in obtaining oral authorization but failing to draft a written competency order, and Appellant demonstrated prejudice by presenting expert testimony that he was incompetent to stand trial at the time of his plea, showing he could have been adjudicated incompetent had a hearing been held.
[1] A defendant may be entitled to relief on an ineffective assistance of counsel claim if counsel's performance was deficient and prejudiced the defendant.
[2] Failure to secure a written order for a mental evaluation, despite oral authorization, can constitute deficient performance by counsel.
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Join FLexlaw to unlock all legal intelligence“When an accused's competency is in doubt, a competency hearing is required.”
Establishes the legal requirement that triggered the failure to provide a hearing
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Join FLexlaw to unlock all legal intelligenceAppellant's counsel obtained oral authorization from the trial judge for a mental evaluation of Appellant but never drafted a written order for the ju…
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BROWNING, C.J.
Appellant challenges the denial of his postconviction motion, alleging both fundamental error in that no competency hearing was held, and ineffective assistance of counsel in that counsel did not demand a competency hearing. We affirm as to the claim of fundamental error, without further discussion, but we reverse the ruling on the ineffective assistance claim because Appellant has adequately shown both deficient performance and prejudice under Strickland v. Washington, 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984).
Counsel’s performance was deficient in that he obtained the trial judge’s oral authorization for a mental evaluation of Appellant, but never drafted a written order for the judge to sign, so no competency hearing under Florida Rule of Criminal Procedure 3.210 was held. When an accused’s competency is in doubt, a competency hearing is required. Rogers v. State, 954 So. 2d 64 (Fla. 1st DCA 2007). The failure to secure a written order so providing constitutes deficient performance and compels relief if Appellant can show prejudice resulting from such failure.
Appellant has shown that his counsel’s deficient performance prejudiced him by the doctor’s testimony adduced at the evidentiary hearing that, in his opinion, Appellant was incompetent to stand trial at the time he entered his plea. This testimony shows that had a competency hearing been held, Appellant could have been adjudicated incompetent to enter his plea of guilty.
For these reasons, we REVERSE the denial of Appellant’s postconviction motion, and REMAND for a competency hearing to determine if Appellant was competent at the time he entered his plea. If Appellant is found incompetent, his conviction and sentence shall be voided. If Appellant is found competent, his sentence and conviction stand.
BARFIELD and DAVIS, JJ„ concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984)
- Rogers v. State, 954 So. 2d 64 (Fla. 1st DCA 2007)