John Robert Quick v. State, 11-15-00179-CR

Appellant John Robert Quick pleaded guilty (third-degree felony: delivery in a drug-free zone) under a plea agreement; sentence of 10 years was suspended and he was placed on community supervision for 10 years.
The State filed a motion to revoke supervision alleging 15 violations (including possession/use of a controlled substance, associating with a felon, failure to report, failure to pay costs/victim fees, and failure to complete restitution).
At the revocation hearing Appellant pled “not true”; the trial court found nine allegations true, revoked supervision, and imposed a 4-year prison term.
Appellant has a diagnosed schizophrenia history, received social security disability income, admitted drug use, and spent about a year incarcerated without mental-health services; he argues these facts raised a competency question requiring a sua sponte informal inquiry under Tex. Code Crim. Proc. art. 46B.004.
At the revocation hearing Appellant: answered the court coherently; acknowledged understanding the charges; knowingly waived medical/psych confidentiality twice so MHMR witnesses could testify; and previously at the plea hearing denied being incompetent after a detailed court inquiry.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by failing to conduct a sua sponte competency inquiry under art. 46B.004	Quick: his schizophrenia, incarceration without mental-health services, admitted substance use, and SSDI status raised a suggestion of incompetence requiring an informal inquiry	State/Trial court: record showed no suggestion of incompetence — Quick understood charges, made strategic waivers, communicated rationally, and the court had previously examined mental-health issues at plea	Court affirmed: no abuse of discretion; the facts did not trigger a competency inquiry

Montoya v. State, 291 S.W.3d 420 (Tex. Crim. App. 2009) (trial court in better position to assess present competency; review for abuse of discretion)
Turner v. State, 422 S.W.3d 676 (Tex. Crim. App. 2013) (temporary mental illness does not automatically require competency inquiry; focus on capacity to consult rationally and understand proceedings)
Lindsey v. State, 310 S.W.3d 186 (Tex. App.—Amarillo 2010) (no error in failing to conduct sua sponte inquiry where defendant’s responsive, rational answers indicated understanding)