Jones v. State
125 So. 3d 982
| Fla. Dist. Ct. App. | 2013Background
- Jones appeals an order denying his amended motion to withdraw his no-contest pleas to felony battery, resisting an officer with violence, possession of cannabis with intent to sell, possession of alprazolam, and driving with a suspended license.
- Jones was previously declared incompetent and committed to a state mental health facility.
- After incompetence, Jones petitioned for a competency hearing; two expert evaluations found him competent, and the court admitted the reports in lieu of live testimony.
- The court declared Jones competent to proceed and he pled no contest to the charges, later violating probation.
- Jones moved to withdraw his pleas arguing the competency hearing was insufficient; the trial court held multiple hearings and found a full competency hearing under Rule 3.212(c)(7) occurred.
- The appellate court affirmed, holding the written reports, with stipulation of the parties, sufficed to determine competency.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a proper competency hearing under Rule 3.212 before the pleas? | Jones argues Macaluso requires live testimony even with stipulations. | State contends stipulation to expert reports suffices for competency. | Yes; the hearing was proper under Rule 3.212. |
Key Cases Cited
- Samson v. State, 853 So.2d 1116 (Fla. 4th DCA 2003) (reversed for lack of hearing when no competency order or hearing occurred)
- Fowler v. State, 255 So.2d 513 (Fla.1971) (courts may rely on written reports if parties agree)
- Molina v. State, 946 So.2d 1103 (Fla.5th DCA 2006) (trial court may consider reports to determine competency with agreement of parties)
- Macaluso v. State, 12 So.3d 914 (Fla.4th DCA 2009) (Rule 3.212 does not sanction stipulations to ultimate issue of competency; here, relied on stipulations per rule)