Jeremiah Anthony Marshall, a/k/a Jeremiah Anthony Mahoney v. State, 2016 WY 119

Marshall was arrested after a traffic stop; officers found methamphetamine and charged him with felony possession, misdemeanor interference, and forgery (forgery later dismissed).
Defense counsel initially moved for a competency evaluation based on Marshall’s reported traumatic brain injury and odd behavior; the court ordered an inpatient evaluation at Wyoming State Hospital.
Dr. David Carrington evaluated Marshall for ~6 weeks and reported Marshall had both factual and rational understanding of charges and was fit to proceed despite some personality-driven, possibly paranoid behaviors.
The court held a contested competency hearing, received Dr. Carrington’s testimony, and found Marshall competent; trial proceeded, resulting in a misdemeanor conviction (interference) and a mistrial on the felony possession count.
Months later Marshall sought a second competency evaluation alleging deterioration (refusing to eat, refusing counsel); defense withdrew that motion when Marshall entered an Alford plea to the felony possession charge, which the court accepted after finding him competent to plead.
Marshall appealed, arguing the court erred by not ordering a second competency evaluation; the Wyoming Supreme Court consolidated his appeals and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred in refusing to suspend proceedings and order a second competency evaluation	Marshall: A new motion alone and post-evaluation behavior created "reasonable cause" requiring a second evaluation under § 7-11-303	State: A second evaluation is required only if there is new "reasonable cause" beyond the motion itself; prior evaluation and report showed no new basis	Court: Motion alone does not establish reasonable cause; substantial evidence supported denial because complained-of behaviors were already addressed in initial evaluation and Marshall was competent to plead
Whether alleged failure to order second evaluation requires reversal of earlier misdemeanor conviction	Marshall: Denial tainted both convictions	State: Misdemeanor conviction preceded later conduct; no basis to overturn	Court: Summarily affirmed misdemeanor—Marshall offered no persuasive argument tied to the earlier conviction

Schaeffer v. State, 268 P.3d 1045 (Wyo. 2012) (substantial-evidence standard governs review of competency determinations)
Fletcher v. State, 245 P.3d 327 (Wyo. 2010) (framework for competency review cited)
Godinez v. Moran, 509 U.S. 389 (1993) (competency standard—ability to consult with lawyer and rational/factual understanding)
Dusky v. United States, 362 U.S. 402 (1960) (articulation of competency standard)
Follett v. State, 132 P.3d 1155 (Wyo. 2006) (continuing duty to monitor competency but additional evaluations require reasonable cause)
deShazer v. State, 74 P.3d 1240 (Wyo. 2003) (distinguishable; facts presented strong evidence of incompetency and court failed to evaluate)
Major v. State, 83 P.3d 468 (Wyo. 2004) (competence to stand trial equals competence to plead)