State v. Hollars, 376 N.C. 432

Defendant Hollars was charged in 2012 with multiple counts of second‑degree sexual offense and taking indecent liberties with a child; trial occurred January 2018 after repeated competency proceedings over ~6 years.
Medical history: diagnoses including schizophrenia/schizoaffective disorder, bipolar disorder, and mild neurocognitive disorder; seven forensic evaluations over time with divergent findings (some finding incompetent, later reports finding competence after treatment/medication).
On 5 September 2017 three psychiatrists (Bartholomew, Utterback, and Bellard after consultation) had concluded Hollars was competent; trial was set but postponed, creating a ~4‑month gap before January 2018 trial start.
On the third day of trial (Jan 10, 2018) defense counsel reported a brief conversation in which Hollars said he did not know what was going on; counsel asked the court to query Hollars about competency. The court deferred questioning to the next morning.
The next morning defense counsel reported no continuing concern; the trial court did not question Hollars and the trial proceeded. Jury convicted on all counts and trial court imposed lengthy consecutive sentences.
Court of Appeals (majority) held the trial court should have initiated a sua sponte competency hearing; the Supreme Court of North Carolina affirmed, finding substantial evidence of a bona fide doubt and remanding per the Court of Appeals’ instructions.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hollars)	Held
Whether the trial court had a constitutional duty to institute a sua sponte competency hearing at or immediately before trial	Prior competency finding (Sept 2017) by multiple psychiatrists negated reason to doubt competence; no substantial evidence at trial start	Long history of fluctuating competency, multiple prior findings of incompetence, and the in‑trial episode (defendant saying he didn’t know what was happening) created a bona fide doubt	Court held there was substantial evidence raising a bona fide doubt and the trial court erred by not initiating a competency inquiry sua sponte
Remedy if duty was violated: whether reversal/new trial or retrospective hearing is required	If retrospective determination possible, no new trial required if defendant was competent at trial	Requested a new trial if competency cannot be reliably determined retrospectively	Court affirmed Court of Appeals: remand for trial court to determine whether a meaningful retrospective competency hearing is possible; if not, convictions reversed and new trial when competent; if yes and found competent, convictions stand

Cooper v. Oklahoma, 517 U.S. 348 (defendant must be competent; standards for competency challenges)
Drope v. Missouri, 420 U.S. 162 (factors establishing bona fide doubt: irrational behavior, demeanor, prior medical opinion)
Godinez v. Moran, 509 U.S. 389 (competency inquiry required only when court has reason to doubt competency)
State v. Badgett, 361 N.C. 234 (trial court must institute sua sponte competency hearing if substantial evidence of incompetence exists)
State v. King, 353 N.C. 457 (prior treatment alone may be insufficient; court must consider Drope factors)
State v. Cooper, 286 N.C. 549 (competency judged at time of trial)
State v. McRae, 139 N.C. App. 387 (procedure on remand: retrospective competency hearing guidance)