Summary 2010 WY 167

Summary of Decision December 21, 2010

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Case Name: Fletcher v. State

Citation: 2010 WY 167

Docket Number: S-09-0258

URL: http://tinyurl.com/233h5fq

Appeal from the District Court of Park County, Honorable Steven R. Cranfill, Judge

Representing Appellant (Defendant):

Representing Appellee (Defendant):

Date of Decision: December 21, 2010

Facts: Appellant pleaded guilty to attempted manslaughter, but challenges the district court’s findings of his competence to proceed both to trial and sentencing. Appellant also disputes the court’s denial of his motion to change his plea to “not guilty by reason of mental illness or deficiency.”

Issues: Whether the trial court erred in its decisions that Appellant was competent to proceed to trial and to sentencing. Whether trial court erred in refusing to allow Appellant to change his plea to “not guilty by reason of mental illness or deficiency.”


Holdings: A criminal defendant may not be tried unless he is competent, and he may not waive his right to counsel or plead guilty unless he does so “competently and intelligently.” The same standard of competency applies whether a defendant goes to trial or pleads guilty. A defendant is competent, under the standards of due process, if he has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding and has a rational as well as factual understanding of the proceedings against him. Wyo. Stat. 7-11-301 et. seq. sets forth the requirements for determining whether a criminal defendant is competent to stand trial. The statutes are designed to protect criminal defendants' due process rights. The statutory requirements pertain to all trial court proceedings, including change of plea proceedings.

During Appellant’s competency hearing, two doctors testified at length about the findings in their evaluations, each doctors reaching different conclusions. Taking both doctors’ testimonies into account, the court found Appellant competent to proceed to trial, as he had the capacity to comprehend his position, and he understood the nature and the object of the proceedings. When a district court is faced with conflicting expert reports, it does not clearly err simply by crediting one opinion over another where other record evidence exists to support the conclusion. Appellant raised his competency, yet again, on the day of sentencing and a further examination was ordered to determine Appellant’s competency to proceed to sentencing. It was concluded that Appellant did appear to have a chronic mental illness but that it did not interfere with his competency to proceed to sentencing.

Since the Appellant underwent an initial competency examination by two doctors, and an additional evaluation prior to sentencing, the district court had abundant information from which to determine his competency and to decide to utilize the information on hand rather than order additional studies. It did not abuse its discretion in finding Appellant competent to proceed to sentencing.

Appellant argues good cause existed for him to change his plea. Although experts differed as to the mental status of Appellant, the court had already credited one doctor’s evaluation over the other. Also, the record is clear that Appellant’s not guilty plea was not entered into by mistake, inadvertence, or ignorance. In fact, defense counsel considered the alternative, which was to add an accompanying plea of not guilty by reason of mental illness. Moreover, during his arraignment, Appellant acknowledged that he understood his right to plead however he wanted. Defense counsel conceded during the motion to amend plea hearing that a not guilty by reason of mental illness plea had been “considered and evaluated” prior to arraignment. There is no right to a continual succession of competency hearings in the absence of some new factor, and the Wyoming Rules of Criminal Procedure do not place a duty on the trial judge to hold hearing after hearing in the absence of some appearance of change in the defendant’s condition since the ruling on competency was originally made. Here, the district court did not abuse its discretion when it denied Appellant’s motion to change his plea, as it did not consider there was good cause to do so.

The district court did not err when it found Appellant competent to proceed to trial and to sentencing. Furthermore, the district court did not abuse its discretion when it denied Appellant’s motion to add to his plea of not guilty, a plea of not guilty by reason of mental illness. The district court’s judgment and sentence are affirmed.

J. Hill delivered the opinion for the court.