Fletcher v. State, 2010 WY 167

Fletcher was charged with attempted first-degree murder and reckless endangering after July 9, 2007 shooting at a Cody Walmart.
Initially, a competency motion under §7-11-303 was granted, and Buckwell concluded no mental illness and competence to proceed.
Holmberg later evaluated Fletcher as not competent due to alleged mental illness and cognitive deficits.
Two doctors' opinions conflicted: Buckwell found competence; Holmberg found incompetence.
Fletcher pleaded guilty to attempted manslaughter on Sept. 19, 2008.
Sentencing occurred April 24, 2009 after Dillinger found Fletcher competent for sentencing; Fletcher then appealed the competence rulings and the denial of a motion to amend his plea.
The district court denied Fletcher’s motion to amend the plea to not guilty by reason of mental illness, which Fletcher challenged on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competence to proceed to trial and sentencing	Fletcher argues lack of competence.	Fletcher contends his mental state rendered him incompetent.	Court supported competence to proceed to trial and sentencing.
Right to amend plea to not guilty by reason of mental illness	Fletcher argues good cause existed to amend plea.	State contends no good cause. defense explored alternatives.	District court did not abuse discretion; denial affirmed.

Follett v. State, 132 P.3d 1155 (Wy. 2006) (competency standard; de novo review of legal standard; process sufficiency)
deShazer v. State, 74 P.3d 1240 (Wyo. 2003) (competency must be evaluated by proper standard; substantial evidence review)
Godinez v. Moran, 509 U.S. 389 (U.S. 1993) (competence to plead and stand trial standard (Dusky-based) applies to guilty pleas as well)
Wilkening v. State, 120 P.3d 680 (Wy. 2005) (pre-trial competency evaluation; timing of plea change; good cause analysis)
Mozee v. Commonwealth, 769 S.W.2d 757 (Ky. 1989) (limitations on continuing competency hearings absent new factors)