Jeremiah Anthony Marshall, a/k/a Jeremiah Anthony Mahoney v. State

Summary

The Wyoming Supreme Court affirmed Jeremiah Anthony Marshall’s convictions for felony possession of methamphetamine and misdemeanor interference with a peace officer. The court held that the district court was not required to order a second competency evaluation because the defense motion alone did not establish reasonable cause to believe Marshall was unfit to proceed, and the record provided substantial evidence supporting the court’s competency determinations.

Holdings

1. A motion to suspend proceedings and obtain a competency evaluation does not, by itself, establish reasonable cause to believe that the defendant has a mental illness or deficiency rendering him unfit to proceed and therefore does not automatically compel the district court to suspend proceedings or order an evaluation.
2. The district court did not err in declining to order a second competency evaluation because the record contained substantial evidence supporting its determination that no new information created reasonable cause to believe Marshall was unfit to proceed.
3. The court summarily affirmed Marshall's interference-with-a-peace-officer conviction because he provided no cogent argument or pertinent legal authority connecting the alleged competency error to that conviction.

Questions Presented

1. Whether the district court was required under Wyo. Stat. Ann. § 7-11-303 to suspend proceedings and order a second competency evaluation merely because a motion requesting one was filed.
2. Whether the record supplied reasonable cause to believe that Marshall had developed a mental illness or deficiency making him unfit to proceed.
3. Whether Marshall's unsupported challenge warranted reversal of his misdemeanor interference conviction.

Disposition

affirmed