United States v. Barajas, 20-10582

Marco Barajas pled guilty to conspiracy to distribute and possess with intent to distribute methamphetamine; sentenced to 198 months' imprisonment and appealed.
Barajas later argued the district court should have sua sponte ordered a competency hearing before accepting his guilty plea.
Evidence cited by Barajas: a prior gunshot wound to the head (coma, residual ballistic fragments), reported seizures, memory/coordination issues, a past bipolar diagnosis, temporary SSDI, and PSR notes that he reported hearing voices and seeing shadows while incarcerated.
At the preliminary detention hearing Barajas’s mother testified about his head injury and short-term memory problems but also that he held employment.
At the plea hearing Barajas answered the court coherently, confirmed understanding of the factual resume, and his attorney stated he had no reason to doubt Barajas’s competence or that the plea was knowing and voluntary.
The district court accepted the plea, finding Barajas competent; the Fifth Circuit reviewed whether the record presented reasonable cause to order a competency evaluation and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by failing to sua sponte order a competency hearing before accepting Barajas’s guilty plea	United States: no reasonable cause existed to doubt competency based on the record; court acted within its discretion	Barajas: head wound, seizures, SSDI, self-reported hallucinations and diagnoses raised a bona fide doubt as to competence	Affirmed — no abuse of discretion/plain error; record did not supply reasonable cause to order a competency hearing

Pate v. Robinson, 383 U.S. 375 (1966) (due process requires competency hearing if evidence raises bona fide doubt about competence)
Medina v. California, 505 U.S. 437 (1992) (competency focuses on capacity to participate and understand proceedings)
United States v. Messervey, 317 F.3d 457 (5th Cir. 2002) (district court discretion in ordering competency evaluation; factors to consider)
United States v. Joseph, 333 F.3d 587 (5th Cir. 2003) (definition of competency to stand trial)
United States v. Williams, 819 F.2d 605 (5th Cir. 1987) (information that should reasonably raise a doubt about competence)
United States v. Davis, 61 F.3d 291 (5th Cir. 1995) (standard of review—abuse of discretion—on competency-sua-sponte issue)
United States v. Mitchell, 709 F.3d 436 (5th Cir. 2013) (mental illness not dispositive; overall ability to understand proceedings controls)
Mata v. Johnson, 210 F.3d 324 (5th Cir. 2000) (presence or absence of mental illness does not alone determine competence)