Washington v. McCarthy (Majority)Annotate this Case
In 2014, Matthew McCarthy approached a stranger's home under a mistaken belief that he would find his ex-wife inside. He forced his way in and pushed the occupant against the wall. He returned twice the next evening: the first time once again looking for his ex-wife and the second time looking for his cell phone. Out of these events, the State charged McCarthy with first-degree burglary predicated on assault.The State notified him that this was a most serious offense and that he was facing life in prison without parole due to his criminal history. Prior to McCarthy's arraignment, his public defender expressed her concerns to the court that regarding McCarthy's competency to stand trial. The trial court ordered a competency evaluation and stayed the proceedings. McCarthy objected to the initiation of competency proceedings against his will because he believed himself to be competent. McCarthy was diagnosed with bipolar disorder with nonbizarre delusions, and various substance abuse disorders. While the physician-evaluator initially found McCarthy had a detailed understanding of the legal proceedings, on second review McCarthy was deemed incompetent, and a 90-day restoration was ordered. At issue before the Washington Supreme Court was: (1) whether under RCW 10.77.060(1)(a), the trial court erred during trial, in not ordering a third competency hearing after a jury had previously found McCarthy competent; and (2) what deference, if any, is given to a trial court when it does not sua sponte order a competency hearing. The Washington Supreme Court reversed the Court of Appeals, finding the proper standard of review was abuse of discretion, and the trial court did not abuse its discretion when it did not sua sponte order a competency evaluation based on the evidence presented during the criminal proceedings. The matter was remanded for the appellate court to decide the remaining issues raised in McCarthy's personal restraint petition.