240 So. 3d 1243
Miss. Ct. App.2018Background
- Christopher Allen Joiner was indicted on three counts of armed robbery and sought to proceed pro se, noting a prior request for a psychological evaluation but providing no basis for it.
- Five months before trial new counsel was appointed; Joiner did not renew the competency request during multiple pretrial appearances and rejected a plea after consulting with counsel and the judge.
- On the first day of trial Joiner again asked for a psychological evaluation; the trial judge denied the request after colloquy with Joiner and his attorney.
- The jury convicted Joiner on all three counts; he received life sentences with counts II and III concurrent and consecutive to count I.
- Joiner moved for a new trial asserting the denial of a competency evaluation was error; the motion was denied and he appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in denying Joiner’s request for a psychological evaluation to determine competency to stand trial and to reject a plea | Joiner argued the court should have ordered a mental evaluation to determine if he was competent to reject the plea and stand trial | State argued Joiner presented no medical or other evidence creating reasonable grounds to suspect incompetence; record showed competent communication and decisionmaking | Trial court did not abuse its broad discretion; no reasonable ground shown and denial was proper; conviction affirmed |
Key Cases Cited
- Lokos v. Capps, 625 F.2d 1258 (5th Cir. 1980) (due-process requirement of competency to stand trial)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (factors relevant to competency inquiry include irrational behavior, demeanor, and prior medical opinion)
- Harden v. State, 59 So. 3d 594 (Miss. 2011) (trial court discretion in ordering competency evaluation)
- Goff v. State, 14 So. 3d 625 (Miss. 2009) (standard for whether information should have alerted judge to competency doubts)
- Jaquith v. Beckwith, 157 So. 2d 403 (Miss. 1963) (requirement of evidence indicating reasonable probability defendant cannot make rational decisions)
- Richardson v. State, 767 So. 2d 195 (Miss. 2000) (movant bears burden to prove incompetence by substantial evidence)
- Coker v. State, 909 So. 2d 1239 (Miss. Ct. App. 2005) (no abuse of discretion where no proof presented that evaluation was needed)