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6th DCAMay 31, 2024Decided⭐ Notable

Antonio Reyes Reina v. State

Case No. 6D2023-3738

Reina, found incompetent to proceed due to intellectual disability, moved to dismiss charges under section 916.303(1) after two years of continued incompetency. The trial court denied dismissal and ordered re-evaluation without making the statutorily required findings that he would become competent in the foreseeable future and specifying a time frame. The Sixth DCA granted certiorari and quashed both orders, finding the trial court departed from essential requirements of law by failing to make the necessary statutory findings.

Key facts

  • Reina was found incompetent to proceed due to intellectual disability and remained incompetent after two years of continued evaluation and treatment.
  • Reina moved to dismiss charges under section 916.303(1), but the trial court denied the motion and ordered re-evaluation without making statutorily required findings that he would become competent in the foreseeable future or specifying a time frame.
  • +1 more key fact with a free trial

Why it matters

This opinion reinforces and applies the strict findings requirement under section 916.303(1) for defendants with intellectual disabilities who remain incompetent beyond two years, joining sister-district precedent… — full analysis with a trial

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