White, Victor, PD-0572-15

Four separate trials were consolidated for one trial with four causes and multiple convictions for attempted capital murder, attempted murder, and aggravated assault.
Appellant Victor White shot multiple peace officers during a 24-hour standoff after leaving threatening signs and notes about water contamination.
The State’s witnesses described officers being shot and injured; an armored vehicle was used; ultimately White surrendered after a fire and tear gas.
Pretrial motion by defense counsel to compel a psychiatric competency examination was denied; White expressed dissatisfaction with counsel and briefly contemplated self-representation.
The sole issue on appeal was whether the trial court erred in not sua sponte conducting an informal competency inquiry when evidence potentially raised a bona fide doubt.
The Court of Appeals affirmed, holding no bona fide doubt existed and the informal inquiry was adequate.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court should have sua sponte ordered a competency inquiry	White argues bona fide doubt existed	State contends no doubt warranted inquiry	No error; informally inquired and no bona fide doubt found

Fuller v. State, 253 S.W.3d 220 (Tex. Crim. App. 2008) (requires bona fide doubt to trigger inquiry)
Montoya v. State, 291 S.W.3d 420 (Tex. Crim. App. 2009) (abuse of discretion standard for competency inquiry)
McDaniel v. State, 98 S.W.3d 704 (Tex. Crim. App. 2003) (due process requires competence to stand trial)
Iniquez v. State, 374 S.W.3d 611 (Tex. App.—Austin 2012) (definition of competency and inquiry process)
Turner v. State, 422 S.W.3d 676 (Tex. Crim. App. 2013) (amended statute impact on bona fide doubt standard)
Kostura v. State, 292 S.W.3d 746 (Tex. App.—Houston [14th Dist] 2009) (evidence of doubt must be present to trigger inquiry)
Alcott v. State, 51 S.W.3d 596 (Tex. Crim. App. 2001) (bona fide doubt standard explained)