State v. Bailey

In State v. Bailey, 712 P.2d 281 (Utah 1985), Bailey had a history of mental illness. After his arrest on burglary, theft, and habitual criminal charges, Bailey's "behavior was irrational and disoriented," and Dr. Austin, a prison psychiatrist, concluded he was incompetent to stand trial. Id. at 282. The trial court then ordered Dr. Moench and Dr. Austin, two alienists, to examine Bailey. The alienists' reports conflicted. This time, Dr. Austin found Bailey competent, and Dr. Moench found him incompetent. Therefore, the court ordered Dr. Moench and a third alienist to reexamine Bailey. Both found him competent to stand trial, and he was then tried. Following his conviction, Bailey appealed, alleging the trial court had erred in not holding a competency hearing. The Court held that the evidence did not mandate a hearing on the issue of competency as the most recent examinations found him competent to stand trial. See id. at 285.