Peaks v. State, 18 A.3d 917

Peaks was charged in Baltimore City with attempted first degree murder, attempted first degree rape, first and second degree assault, and weapons offenses, plus narcotics offenses.
Defense raised competency and the court ordered a competency evaluation under Md. Crim. Proc. Code §3-105 after initial concerns.
The Circuit Court initially found Peaks competent to stand trial after evaluations, then ordered a second evaluation.
That second evaluation was not completed because Peaks refused cooperation, but the trial proceeded with a different judge.
Judge Williams later ordered reconsideration of Peaks's competency under §3-104(c); Judge Alpert presided at trial and Peaks was ultimately convicted in absentia with lead counsel from the Public Defender’s Office.
The Court of Special Appeals affirmed; the Maryland Court of Appeals held that the trial court properly addressed competency under §3-104, with no requirement for an explicit separate hearing and with consideration of evidence on the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §3-104(a) required an explicit on-record competency determination before trial	Peaks argues no explicit record was necessary until trial began.	State contends a factual record suffices; an express hearing is not always required.	No strict separate hearing required; record evidence suffices.
Whether a trial court must make an explicit on-record competency determination before a defendant can discharge counsel	Peaks asserts lack of explicit pre-discharge determination invalidated proceedings.	State argues prior on-record observations and evidence supported competency; discharge could occur.	Courts may rely on record evidence and prior determinations; explicit pre-discharge finding not required.
Whether the December 2006 competency reevaluation order triggered §3-104(a) timing concerns	Peaks contends reevaluation order before trial violated timing requirements.	Williams’s order was a reconsideration under §3-104(c), not a new §3-104(a) trigger.	Order was a discretionary §3-104(c) reconsideration, not a new §3-104(a) trigger.
Whether substantial evidence on the record supported Peaks’s competency after reevaluation could not be completed	There was insufficient post-order evidence due to uncompleted evaluation.	Judge Alpert could rely on prior record and behavior observations to assess competency.	Competency upheld based on evidence on the record; lack of completed evaluation did not rebut prior determinations.

Jones v. State, 280 Md. 282 (1977) (record must reflect competency determination on the record)
Roberts v. State, 361 Md. 346 (2000) (trial court must allow evidence; competency decision on record)
Sangster v. State, 312 Md. 560 (1988) (evidence on the record may include medical reports; live testimony not always required)
Trimble v. State, 321 Md. 248 (1990) (pretrial competency determination; no automatic additional hearing when behavior is disruptive)
Jones v. State, 280 Md. 282 (1977) (emphasizes that competency review must be on the record)