Sandra Morgan v. State of Mississippi, 230 So. 3d 748

Sandra Morgan lived with her husband Billy and, in 2014, allowed Devonta Anderson and others to stay in the home; she had recently received insurance proceeds and bought gifts for Anderson.
Morgan allegedly asked Anderson to kill Billy; Anderson went to the bedroom with a gun but ultimately did not shoot after Morgan suggested Billy’s aunt would also have to be killed.
Levontaye and Anderson told law enforcement about the plot; Morgan voluntarily went to the sheriff’s department on August 4, 2014, signed a Miranda waiver, and gave a partially recorded statement; she was arrested and jailed.
On August 11, 2014, Morgan asked to speak with Investigator Rodriguez, denied having counsel, signed another Miranda waiver, and gave a fully recorded second statement implicating herself in a conspiracy.
Pretrial, Morgan moved for a psychiatric (competency) evaluation and to suppress both statements; the trial court denied the competency motion (finding insufficient evidence) and suppressed only the first, partially recorded statement but admitted the second as voluntary.
A jury convicted Morgan of conspiracy to commit capital murder and sentenced her to 15 years (5 suspended); she appealed asserting error in denial of a competency evaluation and in admitting the second statement.

Issue	Morgan's Argument	State's Argument	Held
Whether trial court erred by denying motion for psychiatric/competency evaluation	Morgan argued she suffered from bipolar/depression, took multiple meds, and showed confusion on bail—trial court should have ordered evaluation	State argued defense presented only lay testimony (husband) and no medical records or expert proof to raise reasonable doubt about competence	Denied — trial court did not abuse discretion; lay testimony alone was insufficient to show reasonable grounds for competency evaluation
Whether trial court erred by admitting second custodial statement	Morgan argued statements were coerced/involuntary and she was incompetent when she gave them	State argued Morgan voluntarily went to speak, repeatedly waived Miranda, expressly denied having counsel, and appeared lucid to officers	Denied — second statement admissible; officers’ testimony and recorded waiver showed a knowing, voluntary waiver and no manifest error

Goff v. State, 14 So. 3d 625 (Miss. 2009) (standard for when trial judge should be alerted to competency concerns)
Conner v. State, 632 So. 2d 1239 (Miss. 1993) (competency standard quoted)
Weatherspoon v. State, 732 So. 2d 158 (Miss. 1999) (overruled on other grounds noted)
Bradley v. State, 116 So. 3d 1093 (Miss. Ct. App. 2013) (discretionary standard for competency-suspicion determination)
Harden v. State, 59 So. 3d 594 (Miss. 2011) (competency inquiry standard)
Jay v. State, 25 So. 3d 257 (Miss. 2009) (appellate review standard for competency findings)
Martin v. State, 871 So. 2d 693 (Miss. 2004) (standard for overturning competency findings)
Scott v. State, 8 So. 3d 855 (Miss. 2008) (standards for suppression review and proving voluntariness)
Chim v. State, 972 So. 2d 601 (Miss. 2008) (suppression/review framework)
Coleman v. State, 127 So. 3d 161 (Miss. 2013) (Dusky competency formulation applied)
Dusky v. United States, 362 U.S. 402 (U.S. 1960) (federal standard for competency to stand trial)
Evans v. State, 984 So. 2d 308 (Miss. Ct. App. 2008) (trial judge not required to order competency hearing absent reasonable grounds)
Armstead v. State, 978 So. 2d 642 (Miss. 2008) (burden on State to prove confession voluntary)
Agee v. State, 185 So. 2d 671 (Miss. 1966) (testimony of officers can satisfy voluntariness burden)