James Allen Minyard v. North Carolina
DueProcess HabeasCorpus
Whether the trial court violated the petitioner's due process right to a fair trial by failing to hold a competency hearing despite a bona fide doubt as to the petitioner's competence
QUESTIONS PRESENTED There was a bona fide doubt as to Petitioner’s competence to be tried, due to him becoming stuporous and non-responsive in the second day of his two-day trial, his hospitalization for a medical examination, and his confusing testimony. Rather than holding a competency hearing, the trial court determined—based on unconfirmed and conflicting reports—that Petitioner was voluntarily absent due to ingesting drugs, and the trial court completed the trial. Despite medical records that there were no drugs in his system, the state courts have subsequently held that Petitioner’s claim is subject to harmless error review and that he must show that his absence from court caused him prejudice. The questions presented are: L Whether, despite there being a bona fide doubt as to Petitioner’s competence, the trial court violated Petitioner’s Fourteenth Amendment due process right to a fair trial by failing to hold a competency hearing before determining that Petitioner was voluntarily absent and completing the trial. I. Whether a trial court's failure to hold a competency hearing, when there was a bona fide doubt as to the defendant's competence to be tried, is a structural error not subject to harmless error review.