The following excerpt is from U.S. v. Bocage, 15 F.3d 1090 (9th Cir. 1994):
The defendant now argues that the prior convictions violated his due process rights because the state courts accepted his guilty pleas without holding a competency hearing when the state courts had reason to doubt his competency. See Drope v. Missouri, 420 U.S. 162 (1975); Godinez v. Moran, 113 S.Ct. 2680, 2688 n. 13 (1993). We disagree. The mere fact that the defendant is of low moderate intelligence and has had some psychiatric treatment in the past does not automatically require a court to conduct a competency hearing. Only when the trial court has "sufficient doubt of his competence" is further inquiry necessary. Drope, 420 U.S. at 180. Here, unlike the cases relied upon by the defendant, there is no evidence that Bocage acted irrationally or did anything which would lead the state court to believe that the defendant was not competent.
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