“The court of appeals erred in affirming the trial court's judgment because the evidence presented at trial was sufficient to satisfy the statutory standard of ‘some evidence’ necessary to require a ‘formal competency hearing.’”
On the last day of the guilt phase of Boyett’s manslaughter trial, her attorney filed a motion suggesting Boyett was incompetent. The trial court conducted an informal inquiry. Four witnesses testified. Boyett had a prior diagnosis of schizophrenia and bipolar disorder. During trial, Boyett had doodled and written nonsensical sentences in a notebook. In one meeting with the defense team, she seemed more interested in taking a smoke break than discussing her case. The defense accident reconstruction expert believed she wasn’t “processing the information” he was relaying. Boyett’s sister testified that she was behaving unusually, was “fidgety and aggravated,” and “cussing.” She believed Boyett did not have the present ability to talk with her attorney with a reasonable degree of rational understanding. Also, a local attorney had observed her in the courthouse cafeteria that morning talking loudly to herself while fixing a cup of coffee. The trial court found this evidence insufficient to require a formal competence inquiry.
On appeal, Boyett challenged the trial court’s refusal to conduct a formal inquiry and appoint an expert to examine Boyett. The court of appeals rejected the claim. It held that evidence of a mental illness was not enough. Boyett also needed to establish a substantial possibility that the mental illness was what prevented her from engaging with counsel and understanding the proceedings. The court noted that trial counsel had not pointed to any specific problems that he had with her behavior during trial or in his attempts to communicate with her. He also had not seen any evidence to suggest she was incompetent in the many months he had represented her before trial.
Boyett argues that each of the four witnesses individually presented “some” evidence to warrant a formal competence inquiry. He highlights that the witnesses described “specific problems” they observed in Boyett’s behavior.