State v. Miles, 1 CA-CR 16-0061

Defendant William Kevin Miles was arrested after bank staff called police for erratic behavior; officers found a glass pipe and a cigarette pack containing methamphetamine on his person.
Charged with possession of dangerous drugs (class 4 felony) and possession of drug paraphernalia (class 6 felony).
Counsel requested Rule 11 (competency) evaluations twice; the first request was withdrawn, the second proceeded and psychologist Bennette Dawson found Defendant competent.
The court accepted the expert report and found Defendant competent; trial proceeded.
On trial day and while testifying, Defendant made grandiose and delusional statements (claiming to be a bank CEO and owner of thousands of companies), but also demonstrated factual recollection about the arrest and the items found.
Defendant was convicted on both counts and appealed, arguing the court should have ordered additional Rule 11 competency proceedings (including sua sponte) after his testimony and pretrial statements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by refusing to order a new Rule 11 competency hearing (including sua sponte) after Defendant's pretrial and trial-day statements and testimony	State: prior competency finding based on expert report was valid; no new information sufficient to undermine that finding	Miles: his delusional/grandiose statements during the colloquy and on testimony showed he lacked ability to understand proceedings and assist counsel, requiring a new evaluation	Court affirmed: no abuse of discretion. Statements were similar to those before the earlier evaluation and did not present new evidence; Defendant nonetheless demonstrated sufficient factual understanding to be competent

State v. Lewis, 236 Ariz. 336 (App. 2014) (standard of review for competency determinations and deference to trial court)
State v. Glassel, 211 Ariz. 33 (2005) (competency inquiry standard: whether reasonable evidence supports finding of competency)
State v. Kuhs, 223 Ariz. 376 (2010) (due process right not to be tried while incompetent)
Godinez v. Moran, 509 U.S. 389 (1993) (competence is legal standard focused on understanding proceedings and assisting counsel)
Dusky v. United States, 362 U.S. 402 (1960) (foundational competency-to-stand-trial test)
State v. Lynch, 225 Ariz. 27 (2010) (no second competency hearing required absent new information undermining earlier finding)
Bishop v. Superior Court, 150 Ariz. 404 (1986) (trial judge's duty to inquire sua sponte if competency is in doubt)
Cooper v. Oklahoma, 517 U.S. 348 (1996) (constitutional baseline for competency protections)