Gerardo Solis III v. the State of Texas

Summary

The Texas Thirteenth Court of Appeals held that the trial court violated Gerardo Solis III's due process rights by adjudicating him guilty and revoking his community supervision while he was incompetent to stand trial. The court reversed the revocation orders in both cases and remanded for further proceedings.

Holdings

1. A defendant who is incompetent to stand trial may not be adjudicated guilty in a community-supervision revocation or adjudication hearing. Because the undisputed evidence established that appellant was incompetent at the adjudication hearing, the trial court violated his constitutional due process rights by adjudicating him guilty and revoking his community supervision in both cases.
2. When some evidence suggesting that a defendant may be incompetent comes to the trial court's attention, the court must stay the proceedings and conduct a formal competency examination rather than adjudicate the defendant.

Questions Presented

1. Whether the trial court violated appellant's constitutional due process rights by adjudicating him guilty and revoking his community supervision while he was incompetent to stand trial.
2. Whether the trial court abused its discretion by failing to stay the proceedings and conduct a formal competency examination when some evidence suggested appellant might be incompetent.

Disposition

reversed_and_remanded