Boyett v. State, 545 S.W.3d 556

Appellant Crystal Lummas Boyett was tried for manslaughter after a fatal car collision, convicted, and sentenced to 20 years.
During the guilt-innocence phase defense counsel late-filed a "motion suggesting incompetency," recounting recent observations and a prior diagnosis of bipolar schizophrenia.
The trial court held an informal competency inquiry (outside the jury); four witnesses (a defense consultant, a defense expert, appellant's sister, and an observing attorney) testified about bizarre writings, mumbling/talking aloud, flat affect, memory lapses, and poor engagement with defense experts.
The trial court found "not sufficient evidence to support a finding of incompetence" and declined to order a formal psychiatric/psychological evaluation or a formal competency trial.
The court of appeals affirmed, reasoning the record showed indications of competency (counsel’s prior interactions and in‑court demeanor) and concluding appellant failed to show a "substantial possibility" of incompetency.
The Texas Court of Criminal Appeals reversed, holding the court of appeals misapplied the informal-inquiry standard by (1) weighing evidence of competency against evidence of incompetency instead of considering only evidence suggestive of incompetency, and (2) elevating the statutory "some evidence" standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused discretion by denying a formal competency evaluation after the informal inquiry	Boyett: testimony (prior severe mental illness, recent bizarre behavior, inability to understand or assist) constituted "some evidence" that she may be incompetent and required a formal exam/trial	State: testimony showed only irritability, noncooperation, or courtroom boredom; no evidence that mental illness prevented rational understanding or assisting counsel	Reversed: some evidence existed; appellate court erred by weighing competency evidence and by raising the burden above the statutory "some evidence" standard; remand for feasibility of a retrospective competency trial

Turner v. State, 422 S.W.3d 676 (Tex. Crim. App. 2013) (explains statutory "some evidence" standard at informal competency inquiry and that court must consider only evidence tending to show incompetency)
Ex parte LaHood, 401 S.W.3d 45 (Tex. Crim. App. 2013) (discusses evidentiary threshold meaning of more than a scintilla in competency context)