Peaks v. Maryland
Annotate this CasePetitioner Dwayne Peaks was convicted of multiple offenses following a jury trial in circuit court. Petitioner argued that the trial judge did not make an adequate determination of Petitioner’s competency to stand trial under state law. Defense counsel first raised the issue of Petitioner’s competency following his arraignment. The court then ordered an evaluation. The court found that Petitioner was competent to stand trial, but elected to reconsider the matter. A second evaluation was never completed because the case was transferred to another trial judge. Neither party raised the competency issue with the new judge. After advising Petitioner of his rights and plea negotiations, voir dire began. During this process, Petitioner requested to discharge his attorney because he believed the attorney was not adequately representing him. Petitioner sought to continue pro se. The trial judge allowed Petitioner to discharge his attorney. Petitioner became unruly during the remainder of voir dire, and was escorted from the courtroom several times. Voir dire was concluded without Petitioner or defense counsel. The court proceeded with trial, and eventually convicted Petitioner in absentia. Petitioner appealed his conviction through counsel from the Office of the Public Defender, alleging the trial court erred by not performing the second competency evaluation. The Supreme Court held that in light of the circumstances, even though Petitioner’s trial had already commenced, the trial judge did not violate state law by not conducting the second evaluation. The Court affirmed the lower court’s decision.
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