Smith v. State (1994)

In Smith v. State, 871 P.2d 186 (Wyo. 1994), Mr. Smith was charged with two counts of first degree murder. Prior to his arraignment, the trial court ordered the procedures suspended for an evaluation of Mr. Smith's competency to stand trial. Id. at 187. After the trial court determined he was fit to proceed, Mr. Smith was arraigned and pled not guilty and not guilty by reason of mental illness or deficiency. Id. Mr. Smith subsequently changed his plea to guilty. Id. On appeal, this Court concluded his guilty plea was unconditional and, consequently, he waived all non-jurisdictional defenses. Id. at 190. There was no contention that the trial court was required to order Mr. Smith to undergo another competency evaluation simply because he pled not guilty by reason of mental illness after the competency evaluation was completed. Id.