Hicks v. State
The First DCA affirmed convictions for second-degree murder, armed robbery, and burglary, rejecting arguments that the evidence was insufficient for robbery and that the trial court fundamentally erred by proceeding to trial without a competency hearing or written competency order after an expert found the defendant competent. Applying its very recent decision in Awolowo v. State, the court held that absent record evidence raising reasonable doubt about competency, the failure to hold a hearing or enter a written order is not fundamental error even though a competency evaluation was ordered.
Key facts
- Defendant was convicted at trial of second-degree murder, armed robbery, and burglary after the trial court ordered a competency evaluation, which determined defendant was competent.
- Defendant appealed, arguing the evidence was insufficient to sustain the robbery conviction and that the trial court committed fundamental error by failing to hold a competency hearing or enter a written competency order despite ordering the evaluation.
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Why it matters
This opinion reinforces and applies the First DCA's newly-minted rule from Awolowo v. State (decided just days earlier) that a trial court's failure to hold a competency hearing or enter a written competency… — full analysis with a trial
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