PHILLIPS v. STATE (2025)

District Court of Appeal of Florida, First District.

Wayne L. PHILLIPS, Appellant, v. STATE of Florida, Appellee.

No. 1D2024-0993

Decided: May 21, 2025

Jessica J. Yeary, Public Defender, and Ross Scott Haine, II, Assistant Public Defender, Tallahassee, for Appellant. James Uthmeier, Attorney General, and Michael Layton Schaub, Assistant Attorney General, Tallahassee, for Appellee.

We reject Appellant's argument that the trial court fundamentally erred by not holding a competency hearing and entering a finding of competency. See Awolowo v. State, 389 So. 3d 788 (Fla. 1st DCA 2024), review granted, No. SC2024-1165, 2024 WL 5241703 (Fla. Dec. 27, 2024). Here, as in Awolowo, nothing in defense counsel's motion for competency evaluation, the trial court's order authorizing the evaluation, or the record as a whole provided reasonable grounds to believe Appellant was not mentally competent to proceed.

Affirmed.

Per Curiam.

Osterhaus, C.J., and Lewis and Roberts, JJ., concur.

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