State v. Maurice C. Hall, 2013AP209-CR, District 1, 10/15/13; court of appeals decision (not recommended for publication); case activity
A competency evaluation found Hall competent to proceed, though his mental health history caused Deborah Collins, the examiner, to “urge court officers to remain sensitive in the event of any significant changes in his overall mental status as such a factor may signal decline in his competency and warrant his reexamination.” (¶3). On the second day of Hall’s trial, counsel informed the court they had reached a plea agreement, but Hall immediately contradicted that statement. (¶4). After defense counsel noted Hall hadn’t received his medication for two days and that his judgment might be affected, the court questioned Hall, who said he could understand what was going on but that the lack of medication was “clouding” his judgment “a little bit” and that “I just don’t know what to do.” (¶5). The judge concluded Hall was struggling to decide whether to accept the plea agreement and therefore couldn’t “knowingly or voluntarily” enter a plea; that left the “default” option of proceeding with the trial, which resulted in Hall’s conviction. (¶6).
Hall argues that if he couldn’t “knowingly or voluntarily” enter a plea he was also not competent to proceed to trial, for the standard for competence to stand trial and competence to enter a guilty plea are the same. Godinez v. Moran, 509 U.S. 389, 402 (1993); Wis. Stat. § 971.13(1). Therefore, the court should have ordered a new competency evaluation instead of proceeding with the trial. (¶¶8-11). The court of appeals disagrees, concluding the record shows the court didn’t find Hall was not competent to proceed, but only that he was unable to decide whether to accept the plea, and that there was no reason to doubt Hall’s competence to stand trial:
¶12 …. Hall gave appropriate, reasoned answers during his colloquy with the trial court; Hall understood the nature of the charges against him; and Hall understood the consequences of both accepting a guilty plea and proceeding to trial. Dr. Collins’s report indicated that Hall was: intent on maintaining his innocence; “disgust[ed]” by the charges against him; aware of his legal options; and competent to stand trial. The trial court considered Dr. Collins’s report in its decision. Indeed, Hall told the trial court that he was adamant about “clear[ing his] name.” Therefore, it stands to reason that Hall’s colloquy with the trial court reflected the difficulty of deciding whether to accept a guilty plea or continue to maintain his innocence. The colloquy did not demonstrate that Hall lacked the capacity to understand his alternatives and their consequences. Hall told the trial court that he was struggling to make the “serious decision” and changed his mind several times, but that his comprehension was intact. The fact that Hall simply could not decide, even with a somewhat “cloud[ed] judgment,” does not, on the record before us, cast doubt on Hall’s competency to proceed to trial.
