Watts v. Singletary, 87 F.3d 1282 (11th Cir. 1996). · Go Syfert
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Watts v. Singletary, 87 F.3d 1282 (11th Cir. 1996). Cases Citing This Book View Copy Cite
86 citation events (66 in the last 25 years) across 24 distinct courts.
Strongest positive: United States v. Kenneth R. Jackson, Jr., No. 20-10733 (11th Cir. June 1, 2021)
Treatment trajectory · 1996 → 2026 · click a year to view as-of
1996 2011 2026
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At page 1288 Determining competency through defense counsel's assessment19 citing cases[F]ailure of defense counsel to raise the competency issue at trial, while not dispositive, is evidence that the defendant’s competency was not really in doubt . . . .2 citing courts put it this way · 18 listed here
  • United States v. Kenneth R. Jackson, Jr., No. 20-10733 (11th Cir. June 1, 2021).unpublished
    ([F]ailure of defense counsel to raise the competency issue at trial, while not dispositive, is evidence that the defendant’s competency was not really in doubt . . . .)
  • United States v. Eddie Louis Denton, 434 F.3d 1104 (8th Cir. 2006).published 2 cites
    (Because legal competency is primarily a function of defendant's role in assisting counsel in conducting the defense, the defendant's attorney is in the best position to determine whether the defendant's competency is s…)
  • Williams v. Jones (Duval Cnty.), No. 3:18-cv-01103 (M.D. Fla. July 13, 2021).
    Accordingly, failure of defense counsel to raise the competency issue at trial, while not dispositive, is evidence that the defendant’s competency was not really in doubt[.]” Watts v. Singletary, 87 F.3d 1282, 1288 (11th Cir. 1996).
  • Askia Mustafa Raheem v. GDCP Warden, 995 F.3d 895 (11th Cir. 2021).published
    Crumbley said, “[m]y own impression was that he 67 USCA11 Case: 16-12866 Date Filed: 04/26/2021 Page: 68 of 84 was competent”; Futch confirmed, “he was competent to stand trial.” The contemporaneous assessment of trial counsel is particula…
  • Harold Max Pompee v. Sec'y, Florida Dep't of Corr., No. 16-13336 (11th Cir. June 5, 2018).unpublished
    A. Deficient Performance The “defendant’s attorney is in the best position to determine whether the defendant’s competency is suspect,” which means that the failure of Pompee’s counsel “to raise the competency issue at [the plea hearing],…
  • William Carman v. Dep't of Corr., 598 F. App'x 706 (11th Cir. 2015).unpublished 3 cites
    It is not as though defense counsel failed to broach the subject of Carman’s competency and, even if that were the case, that would “not [be] dispositive ... [and would serve as] evidence that [Carman’s] competency was not really in doubt.…
  • State v. Wolf, 2014 UT App 18, 319 P.3d 757.published
    And Wolf's attorney, who "is in the best position to determine whether the defendant's competency is suspect," see Watts v. Singletary, 87 F.3d 1282, 1288 (11th Cir.1996), averred that Wolf was unable to "comprehend and appreciate the char…
  • Melvin Newman v. Rick Harrington, 726 F.3d 921 (7th Cir. 2013).published
    A defendant’s role in assisting counsel in his own defense is to “recognize and relat[e] relevant information to counsel and make the few trial-related decisions reserved for defendants (i.e., whether to plead guilty, whether to request a…
  • United States v. Lazaro Mateo, 413 F. App'x 197 (11th Cir. 2011).unpublished
    “Because legal *203 competency is primarily a function of [a] defendant’s role in assisting counsel in conducting the defense, the defendant’s attorney is in the best position to determine whether the defendant’s competency is suspect.” Wa…
  • United States v. Jeffery Charles Nicoll, Jr., 400 F. App'x 468 (11th Cir. 2010).unpublished 2 cites
    “Because legal competency is primarily a function of defendant’s role in assisting counsel in conducting the defense, the defendant’s attorney is in the best position to determine whether the defendant’s competency is suspect.” Watts v. Si…
Show 8 more citing cases
  • United States v. Saingelus Saingerard, 394 F. App'x 641 (11th Cir. 2010).unpublished 2 cites
    (finding that counsel’s failure to raise the issue of competency is evidence that competency was not in doubt)
  • United States v. David Johnson, 295 F. App'x 342 (11th Cir. 2008).unpublished 2 cites
    Pate v. Robinson, 383 U.S. 375, 385 , 86 S.Ct. 836, 842 , 15 L.Ed.2d 815 (1966); Watts v. Singletary, 87 F.3d 1282, 1287 (11th Cir.1996).
  • State v. Davis, 130 P.3d 69 (Kan. 2006).published 2 cites
    As defense counsel, Rrunson was in the best position to determine whether Davis’ competency was suspect (see Watts v. Singletary, 87 F.3d 1282, 1288 [11th Cir. 1996]), and his 2003 testimony is uncontroverted about the events surrounding h…
  • Colburn v. Cockrell, No. 01-20782 (5th Cir. May 13, 2002).unpublished 2 cites
    See Medina v. California, 505 U.S. 437, 450 (1992) (stating that “defense counsel will often have the best-informed view of the defendant’s ability to participate in his defense”); see also Bryson v. Ward, 187 F.3d 1193, 1201 (10th Cir. 19…
  • Hastings v. Yukins, 194 F. Supp. 2d 659 (E.D. Mich. 2002).published
    Watts v. Singletary, 87 F.3d 1282, 1288 (11th Cir.1996).
  • United States v. Lonnise Andrews, No. 24-10334 (11th Cir. July 7, 2025).unpublished
    See Watts v. Singletary, 87 F.3d 1282, 1288 (11th Cir. 1996).
  • United States v. Joel Steinger, 631 F. App'x 915 (11th Cir. 2015).unpublished
    See Watts v. Singletary, 87 F.3d 1282, 1288 (11th Cir. 1996). 4 .
  • Bryson v. Ward, 187 F.3d 1193 (10th Cir. 1999).published 2 cites
    See Watts v. Singletary, 87 F.3d 1282, 1288 (11th Cir. 1996).
At page 1287 Determining when a competency hearing is required12 citing cases�‘there is no constitutional prohi- bition against the trial and conviction of a defendant who fails to pay attention in court—whether out of indifference, fear, confusion, boredom, or sleepiness— unless that defendant also cannot understand the nature of the proceedings against him or adequately a…1 citing court put it this way
  • Tassin v. United States, No. 9:23-cv-81451 (S.D. Fla. Apr. 10, 2024).
    Counsel does not have an obligation to seek a competency evaluation unless he has a “‘bona fide doubt’ as to the defendant’s competency.” Watts v. Singletary, 87 F.3d 1282, 1287 (11th Cir. 1996); see also Collier v. Fla. Dep’t of Corr.
  • Trueblood v. Dixon, No. 4:21-cv-00019 (N.D. Fla. Sept. 30, 2021).
    The Eleventh Circuit has held that “[i]f the trial court fails to order a competency hearing at trial when one is warranted, the state may still attempt to prove that the defendant was in fact competent at the time of trial at a nunc pro t…
  • State v. Skok, 318 Conn. 699 (2015).published
    (�‘there is no constitutional prohi- bition against the trial and conviction of a defendant who fails to pay attention in court—whether out of indifference, fear, confusion, boredom, or sleepiness— unless that defendant…)
  • United States v. Johnnie Duane Johns, 390 F. App'x 963 (11th Cir. 2010).unpublished
    “Relevant information may include evidence of a defendant’s irrational behavior, demeanor at trial, or. prior medical opinion, but ‘there are, of course, no fixed or immutable signs which invariably indicate the need for further inquiry to…
  • United States v. David Johnson, 295 F. App'x 342 (11th Cir. 2008).unpublished 2 cites
    Pate v. Robinson, 383 U.S. 375, 385 , 86 S.Ct. 836, 842 , 15 L.Ed.2d 815 (1966); Watts v. Singletary, 87 F.3d 1282, 1287 (11th Cir.1996).
  • Magwood v. Culliver, 481 F. Supp. 2d 1262 (M.D. Ala. 2007).published 2 cites
    Watts v. Singletary, 87 F.3d 1282, 1287 (11th Cir.1996); see also id. at 1290 (“Courts in habeas corpus proceedings should not consider claims of mental incompetence to stand trial where the facts are not sufficient to positively, unequivo…
  • United States v. Frank Fernandez, United States of Am. v. Roy Gavaldon, AKA Spider, United States of Am. v. David Gonzales-Contreras, AKA David Contreras-Gonzalez, United States of Am. v. Dominick Shewmaker Gonzales, AKA Solo, AKA Dominick Gonzales, United States of Am. v. Jimmy Sanchez, AKA Seal D, AKA Smokey, United States of Am. v. Suzanne Schoenberg Sanchez, 388 F.3d 1199 (9th Cir. 2004).published
    See Williams v. Woodford, 306 F.3d 665, 704 (9th Cir.2002) ("To the extent that Williams's dazed or inattentive demeanor was before the trial judge, we agree with the Eleventh Circuit that `there is no constitutional prohibition against th…
  • United States v. Fernandez, 388 F.3d 1199 (9th Cir. 2004).published
    See Williams v. Woodford, 306 F.3d 665, 704 (9th Cir.2002) (“To the extent that Williams’s dazed or inattentive demeanor was before the trial judge, we agree with the Eleventh Circuit that ‘there is no constitutional prohibition against th…
  • Stanley Williams v. Jeanne S. Woodford, Warden, California State Prison, San Quentin, 384 F.3d 567 (9th Cir. 2004).published 2 cites
    To the extent that Williams’s dazed or inattentive demeanor was before the trial judge, we agree with the Eleventh Circuit that “there is no constitutional prohibition against the trial and conviction of a defendant who fails to pay attent…
  • Stanley Williams v. Jeanne Woodford, Warden, California State Prison, San Quentin, 306 F.3d 665 (9th Cir. 2002).published 2 cites
    To the extent that Williams’s dazed or inattentive demeanor was before the trial judge, we agree with the Eleventh Circuit that “there is no constitutional prohibition against the trial and conviction of a defendant who fails to pay attent…
Show 2 more citing cases
  • Colburn v. Cockrell, No. 01-20782 (5th Cir. May 13, 2002).unpublished 2 cites
    See Medina v. California, 505 U.S. 437, 450 (1992) (stating that “defense counsel will often have the best-informed view of the defendant’s ability to participate in his defense”); see also Bryson v. Ward, 187 F.3d 1193, 1201 (10th Cir. 19…
  • United States v. Jaime Molina-Garcia, 405 F. App'x 393 (11th Cir. 2010).unpublished
    See United States v. Nickels, 324 F.3d 1250, 1251 (11th Cir.2003). “[I]n order to trigger the trial court’s obligation to order a competency hearing, the court must have information raising a ‘bona fide doubt’ as to the defendant’s compete…
At page 1290 Presenting evidence for substantive incompetence claim5 citing cases
  • May v. Howard, No. 2:24-cv-10829 (E.D. Mich. Apr. 15, 2025).
    Mich. 2002) (quoting Watts v. Singletary, 87 F.3d 1282, 1290 (11th Cir. 1996)).
  • Magwood v. Culliver, 481 F. Supp. 2d 1262 (M.D. Ala. 2007).published 2 cites
    Watts v. Singletary, 87 F.3d 1282, 1287 (11th Cir.1996); see also id. at 1290 (“Courts in habeas corpus proceedings should not consider claims of mental incompetence to stand trial where the facts are not sufficient to positively, unequivo…
  • Thirkield v. Pitcher, 199 F. Supp. 2d 637 (E.D. Mich. 2002).published
    To obtain relief on a substantive incompetence claim, petitioner must present evidence “sufficient to positively, unequivocally, and clearly generate a real, substantial and legitimate doubt as to [his] mental capacity.” Watts v. Singletar…
  • Williams v. Calderon, 41 F. Supp. 2d 1043 (C.D. Cal. 1998).published
    Based on trial counsel’s testimony at the evidentiary hearing and the other evidence presented on Claim A, the Court finds that petitioner failed to present evidence “sufficient to positively, unequivocally, and clearly generate a real, su…
  • Williams v. Calderon, 48 F. Supp. 2d 979 (C.D. Cal. 1998).published
    Substantive Incompetence To obtain relief on a substantive incompetence claim, petitioner must present evidence “sufficient to positively, unequivocally, and clearly generate a real, substantial and legitimate doubt as to [his] mental capa…
At page 1286 Determining competency to stand trial under due process4 citing cases
  • Pollard v. Florida Dep't of Corr., No. 2:22-cv-14290 (S.D. Fla. Apr. 10, 2023). 2 cites
    “The Due Process Clause of the Fourteenth Amendment prohibits the criminal prosecution of a defendant who is not competent to stand trial.” Watts v. Singletary, 87 F.3d 1282, 1286 (11th Cir. 1996).
  • United States v. Alvarado, 643 F. App'x 853 (11th Cir. 2016).unpublished
    Nothing in the record suggests that Alvarado lacked “sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding or a rational as well as a factual understanding of the proceedings against him.”…
  • United States v. Gerry Sanders, 638 F. App'x 946 (11th Cir. 2016).unpublished
    Watts v. Singletary, 87 F.3d 1282, 1286 (11th Cir.1996).
  • United States v. Markeith Cox, 713 F. App'x 891 (11th Cir. 2017).unpublished
    See Watts v. Singletary, 87 F.3d 1282, 1286 (11th Cir. 1996).
At page 1289 holding that, "The competency determination, because it looks to the capacity of a particular defendant to play a fact-specific role at trial, requires a case-by-case assessment.1 citing case1 citing court put it this way
  • People v. Palmer, 31 P.3d 863 (Colo. 2001).published 2 cites
    (holding that, "The competency determination, because it looks to the capacity of a particular defendant to play a fact-specific role at trial, requires a case-by-case assessment.)
Other citing cases3 with no pin cite or quoted language on record
Retrieving the full opinion text from the archive…
Watts
v.
Singletary
95-4403.
Docket on CourtListener (RECAP)
Court of Appeals for the Eleventh Circuit.
Jul 18, 1996.
Published opinion
87 F.3d 1282
1996 WL 362540
Published
[PUBLISH]
IN THE UNITED STATES COURT OF APPEALS

FOR THE ELEVENTH CIRCUIT

No. 95-4403

D.C. Docket No. 94-6258-CIV-UUB

CARL EUGENE WATTS,

Petitioner-Appellee,

versus

HARRY K. SINGLETARY,

Respondent-Appellant.

Appeal from the United States District Court
for the Southern District of Florida

(December 19, 1996)

ON PETITION FOR REHEARING EN BANC

(Opinion July 18, 1996, 11th Cir., 87 F.3d 1282)

Before HATCHETT, Chief Judge, TJOFLAT, KRAVITCH, ANDERSON,
EDMONDSON, COX, BIRCH, DUBINA, BLACK, CARNES and BARKETT, Circuit Judges.
[*~1282–1286]

PER CURIAM:

The Court having been polled at the request of one of the members of the Court and a majority of the Circuit Judges who are in regular active service not having voted in favor of it (Rule[*~1286–1290] 35, Federal Rules of Appellate Procedure; Eleventh Circuit Rule 35-5), the Suggestion of Rehearing En Banc is DENIED.

BARKETT, Circuit Judge, dissenting:

I respectfully dissent from the order of the majority of the court in denying the petition of appellee Carl Watts for en banc rehearing. This case presents important issues which, for reasons stated in Judge Carnes’s dissent, were erroneously decided.