Arnold v. State
214 So. 3d 739
Fla. Dist. Ct. App.2017Background
- Appellant Ob Akeem Rendell Arnold was convicted of robbery while wearing a mask and resisting an officer without violence; he appealed his convictions and sentences.
- At a pretrial competency stage, medical reports evaluated Arnold's competency to proceed.
- The parties stipulated to the findings in the doctor's report that Arnold was competent.
- The trial court announced it was finding Arnold competent "based on the report and the findings contained therein."
- The court did not enter a written competency order adjudicating Arnold competent.
- Appeal contested whether the court fulfilled its duty to independently determine competency and whether a written order was required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court satisfied due process by relying on the parties' stipulation and reports rather than conducting a full competency hearing | Arnold: court deprived him of due process by accepting stipulation without conducting sufficient hearing | State: parties stipulated and court relied on report; no prior incompetency finding existed | Court: Because there was no prior finding of incompetency and the court expressly found competency based on the report, the court made an independent determination; no due process violation |
| Whether the court was required to enter a written competency order | Arnold: absence of written order violates Dougherty requirements | State: oral finding based on report sufficed | Court: Written order is required; remand for entry of a nunc pro tunc competency order |
Key Cases Cited
- Dougherty v. State, 149 So. 3d 672 (Fla. 2014) (trial courts must independently determine competency and enter written orders; parties cannot short-circuit the court's duty by stipulation)
- Holland v. State, 185 So. 3d 636 (Fla. 2d DCA 2016) (remand required to enter nunc pro tunc written competency order)