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Duckett v. State

The trial court did not err in allowing the defendant to represent herself at trial, despite the fact that it became apparent during sentencing that she suffered from some degree of mental or emotional illness.

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Appellant Alaneua Duckett was arrested and charged with aggravated assault, making terroristic threats, simple battery, and criminal trespass following an incident at a hair salon. She represented herself at trial, and a jury found her not guilty of simple battery and guilty of the remaining charges. Duckett, who is now represented by counsel, appeals from the denial of her motion for new trial, arguing that the trial court erred by allowing her to represent herself without first determining if she was competent to do so and by failing to sua sponte investigate her competency during trial.

The evidence, construed to support the jury’s verdict,1 shows that the incident giving rise to the charges against Duckett occurred on Duckett’s first day at work as a stylist at a hair salon owned by Lynn Dozier. Duckett arrived at work on time, but the other salon employee, Shaquera Joyner, was late arriving to open the salon and Duckett became upset. Joyner called Dozier to tell her that Duckett was upset, and Dozier told Joyner that she was on her way and that Joyner should ignore Duckett until she arrived.

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