Deferrell v. State, 199 So. 3d 1056

Deferrell was on four-year probation for attempted burglary of a dwelling and related charges.
In 2012, Deferrell was arrested on new charges, triggering a VOP proceeding.
Multiple hearings occurred; Deferrell sought self-representation (Faretta) and complained about counsel.
In July 2013, competency concerns arose; two prior evaluations found competence but defense urged incompetence.
The court ordered a third competency evaluation and later ordered another exam for pro se capability; the report still found competence.
In August 2013, a nonjury trial on the new charges and VOP was held; Deferrell was found to have violated probation and sentenced to 48 months, with sentences concurrent to two felonies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred in not conducting a competency hearing	Deferrell argues Rule 3.210(b) required a hearing	State says no hearing needed since reports were competent	Reversed: mandatory competency hearing required and no finding issued
Whether the court erred in not holding a Faretta hearing	Deferrell unequivocally requested self-representation	Court allowed proceedings without Faretta hearing	Reversed: Faretta hearing required; error per se

Williams v. State, 169 So.3d 221 (Fla. 2d DCA 2015) (competency hearing cannot be waived by silence or stipulation when a request for a Nelson/Faretta inquiry exists)
Harden v. State, 152 So.3d 626 (Fla. 3d DCA 2014) (Faretta hearing failure is per se reversible error)
Tennis v. State, 997 So.2d 375 (Fla. 2008) (right to self-representation requires unequivocal request and a hearing to ensure knowing waiver)
McCray v. State, 71 So.3d 848 (Fla. 2011) (quoting Faretta principle on self-representation)
Lindsey v. State, 69 So.3d 363 (Fla. 5th DCA 2011) (waiver analysis for Faretta issues; outlining abandonment considerations)
Dougherty v. State, 149 So.3d 672 (Fla. 2014) (statutory language requiring hearing; written reports are advisory)