Navarro v. State
The Fifth DCA reversed Navarro's convictions and sentences, holding the trial court committed fundamental error by ordering a competency evaluation after finding reasonable grounds to question Navarro's competency, but never making an independent determination of competency to proceed. The court also found reversible error in sentencing Navarro without a Criminal Punishment Code scoresheet. The case was remanded for a nunc pro tunc competency determination (or new trial if not possible) and resentencing with a proper scoresheet if competency is confirmed.
Key facts
- Navarro was convicted and sentenced by the trial court after a competency evaluation was ordered based on a motion alleging specific facts including Baker Act commitments, suicide attempt, head injuries, and substance dependency.
- The trial court found reasonable grounds to question Navarro's competency and ordered an evaluation under Rule 3.210(b), but never made an independent determination of whether Navarro was competent to proceed.
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Why it matters
This opinion is useful to criminal practitioners for its detailed application and distinguishing of Awolowo v. State, clarifying exactly what factual specificity in a competency motion and language in a… — full analysis with a trial
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