Sauls v. State
A juvenile transferred to adult court and represented by counsel throughout, including at his nolo contendere plea, argued on direct appeal that the trial court should have held a competency hearing after his attorney filed (and later withdrew) a Suggestion of Incompetency. The Fifth DCA affirmed, holding that the narrow fundamental-error exception to the preservation requirement recognized in State v. T.G. for uncounseled juvenile pleas does not extend to represented juveniles, consistent with the Florida Supreme Court's treatment of T.G. in State v. Dortch.
Key facts
- Juvenile was transferred to adult court and represented by counsel throughout proceedings, including at his nolo contendere plea.
- Defense counsel filed a Suggestion of Incompetency in the clerk's file, which was later withdrawn, but the trial court never held a competency hearing.
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Why it matters
This opinion reinforces and applies Dortch's narrow reading of the T.G. exception, confirming that represented juveniles (including those transferred to adult court) cannot invoke T.G. to bypass the preservation… — full analysis with a trial
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