Daunte Oats vs State of Florida

Annotate this Case

Download PDF

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA _____________________________ No. 1D15-5169 _____________________________ DAUNTE OATS, Appellant, v. STATE OF FLORIDA, Appellee. _____________________________ On appeal from the Circuit Court for Leon County. James O. Shelfer, Judge. October 3, 2018 PER CURIAM. Daunte Oats raises two issues on appeal: whether the trial court failed to conduct a competency hearing and whether Florida’s 10-20-Life statute is unconstitutional as applied to juveniles. We affirm as to the second issue, but reverse and remand as to the first because it appears no competency hearing occurred. As the State concedes, a determination was made that reasonable grounds existed that Oats was not competent to proceed, but that no competency hearing occurred. We therefore reverse and remand for the trial court to conduct a nunc pro tunc competency evaluation; if one cannot be done, Oats is entitled to a new trial. See, e.g., Brooks v. State, 180 So. 3d 1094, 1096 (Fla. 1st DCA 2015). MAKAR, WINOKUR, and WINSOR, JJ., concur. _____________________________ Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________ Candice Kaye Brower, Criminal Conflict & Civil Regional Counsel, Gainesville, and Michael Jerome Titus, Assistant Conflict Counsel, Tallahassee, for Appellant. Pamela Jo Bondi, Attorney General, and Steven Edward Woods, Assistant Attorney General, Tallahassee, for Appellee. 2

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.