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Antoine L. Bynum v. State
Citation: 247 So. 3d 601Docket: 5D16-3342
Court: District Court of Appeal of Florida; May 7, 2018; Florida; State Appellate Court
Original Court Document: View Document
Antoine L. Bynum, the appellant, challenges his judgment and sentence for the second-degree murder of Remmi Goyens, arguing that the trial court erred fundamentally by not independently determining his competency to proceed. Initially, on April 26, 2015, Bynum's counsel filed a notice of incompetency, leading the court to find him incompetent and commit him to the Department of Children and Families (DCF) for treatment. On August 31, 2015, DCF reported that Bynum's competency was restored, prompting another competency evaluation. However, during the October 22, 2015 hearing, no evidence was presented; counsel simply stated that the expert deemed Bynum competent. The court accepted this without reviewing the report and found him competent, despite the prior determination of incompetence. The court's ruling was reversed, emphasizing that a defendant's legal status does not change solely based on DCF's determination of restored competency. The appellate opinion noted that under Florida law, a criminal proceeding cannot continue if a defendant is deemed incompetent, and once found incompetent, a presumption of continued incompetence exists until a court finds otherwise after proper notice and hearing. The failure to adhere to these procedures constitutes fundamental error, leading to the reversal for a nunc pro tunc competency hearing, while affirming other aspects of the lower court's ruling. The trial court's determination of the Appellant's competency to proceed was flawed due to its reliance on the stipulation of the parties and an expert's report that it did not review. According to established Florida law, a proper competency hearing requires the court to call expert witnesses, assess competence, and issue a formal order. Although parties can agree on competency, the court must independently evaluate the evidence and cannot simply accept stipulations. The appellate court identified this failure as a fundamental error, necessitating a remand for a nunc pro tunc competency hearing. If the trial court determines that the Appellant was competent based on sufficient retrospective evidence, it must issue a written order with findings. Conversely, if the court concludes that a proper evaluation of competency prior to trial is unfeasible or finds the Appellant incompetent, it must grant a new trial. The appellate decision is affirmed in part, reversed in part, and remanded with specific instructions.