People v. Dozier (2025): Competency ≠ Criminal Responsibility – The Appellate Division Distinguishes CPL Article 730 Exams from Psychiatric Defenses

Introduction

In People v. Dozier, 238 A.D.3d 1523 (4th Dep’t 2025), the Appellate Division, Fourth Department, affirmed the conviction of Plush Kevin Dozier for first-degree arson and second-degree attempted murder. The appeal raised familiar Miranda and weight-of-the-evidence questions, but its lasting significance lies in the court’s treatment of ineffective-assistance claims tied to mental-health issues. The panel drew a sharp line between (a) competency examinations ordered under CPL Article 730 and (b) psychiatric defenses that speak to a defendant’s mental state at the time of the crime.

Dozier argued that trial counsel was ineffective for deciding not to pursue an insanity or extreme-emotional-disturbance defense before receiving 730 results. The Fourth Department rejected the argument, holding that Article 730 evaluations are designed solely to determine a defendant’s present ability to understand the proceedings and assist in his defense, and therefore have “little or no chance of success” as a springboard for retroactive mental-state defenses. This reasoning, though grounded in existing statutory language, is now the clearest appellate pronouncement on the subject and will guide future claims of ineffective assistance where counsel forgoes psychiatric defenses.

Summary of the Judgment

County Court convicted Dozier after a jury found he had set fire to his partner and her residence with homicidal intent. On appeal, Dozier challenged:

Admission of his pre-Miranda street statements;
Admission of statements made during police booking;
Courtroom closure under COVID-19 protocols;
Alleged prosecutorial misconduct;
Ineffective assistance of counsel (failure to pursue psychiatric defense; failure to object to alleged misconduct); and
Sentence severity.

The Appellate Division unanimously affirmed, concluding, inter alia, that:

Dozier was not in custody when he spontaneously approached officers; hence Miranda warnings were unnecessary;
The booking-question exception and Dozier’s post-Miranda waiver rendered subsequent statements admissible;
Challenges to courtroom closure and prosecutorial conduct were unpreserved;
Counsel’s strategic decision not to mount a psychiatric defense—particularly before completion of Article 730 exams—did not constitute ineffective assistance; and
The sentence was neither harsh nor excessive.

Analysis

Precedents Cited

The opinion draws on a constellation of Fourth Department and Court of Appeals cases, notably:

People v. Gladney, 235 A.D.3d 1255 (4th Dep’t 2025) – objective custodial inquiry for Miranda purposes;
People v. Yukl, 25 N.Y.2d 585 (1969) – seminal custodial test;
People v. Duda, 45 A.D.3d 1464 (4th Dep’t 2007) – suspect-initiated contact negates custody;
People v. Spirles, 136 A.D.3d 1315 (4th Dep’t 2016) – similar facts on street interaction;
People v. Waggoner, 218 A.D.3d 1221 (4th Dep’t 2023) – booking statements and self-initiated comments;
People v. Oliveras, 21 N.Y.3d 339 (2013) – ineffective assistance for failure to investigate mental health;
People v. Caban, 5 N.Y.3d 143 (2005) and People v. Baldi, 54 N.Y.2d 137 (1981) – standards for meaningful representation;
People v. Hinton, 31 N.Y.2d 71 (1972) – public-trial considerations.

By juxtaposing these authorities, the Fourth Department:

Reaffirmed long-standing Miranda doctrine (Yukl; Gladney) in the context of suspect-initiated encounters (Duda; Spirles);
Relied on Waggoner to sanction booking-process questions where the suspect voluntarily continues dialogue; and
Distinguished Oliveras to deny an ineffective-assistance claim predicated on psychiatric defenses, because counsel’s choice was strategic and supported by statutory purpose (Caban; Baldi).

Legal Reasoning

1. Custody and Street Statements. The court applied the objective test: would a reasonable innocent person feel free to leave? Because Dozier:

Approached officers voluntarily,
Requested a pat-frisk himself, and
Suggested going to the station,

no reasonable person would deem themselves in custody. Thus, the absence of Miranda warnings did not bar admission.

2. Booking-Process Statements. Even had the earlier statements been suppressed (they were not), the booking statements stood on independent footing: Dozier received and waived Miranda rights; he initiated the exchange; and the officers’ questions were “routine” and not designed to elicit incriminating responses. The opinion mirrors federal “booking-question” jurisprudence while citing state precedents (Waggoner, Robinson).

3. Ineffective Assistance & Article 730. The pivotal reasoning unfolds in two steps:

Scope of Article 730. CPL 730.10(1) limits evaluations to “current competency” – the defendant’s present understanding and ability to assist counsel. It does not explore sanity or mental disease at the offense date.
Strategic Assessment. Because Article 730 results seldom aid an insanity or EED defense, counsel could rationally forego such a defense even before receiving the reports. The “little or no chance of success” language echoes the constitutional ineffectiveness test (Caban). The court, citing Baker and Benevento, found counsel’s overall performance meaningful and reasonable.

Impact of the Decision

Although Dozier did not alter the custodial analysis or booking exception, it breaks new ground in crystallizing the doctrinal separation between:

Competency to stand trial (CPL 730, a procedural safeguard), and
Mental-state defenses (insanity, extreme emotional disturbance, diminished capacity).

Practically, the case:

Equips prosecutors to rebuff claims that failure to await 730 results before tactical decisions is per se deficient;
Instructs defense attorneys that Article 730 findings are, by design, poor substitutes for a full forensic psychiatric work-up addressing criminal responsibility;
Signals to trial judges that ineffectiveness claims premised on that conflation are likely meritless unless the record shows counsel ignored other psychiatric leads (Oliveras scenario); and
May reduce appellate litigation over strategic choices surrounding mental-health defenses, thereby streamlining post-conviction review.

Complex Concepts Simplified

Miranda Custody: A person is “in custody” when, viewed objectively, a reasonable innocent person would feel they were not free to leave. Voluntary approaches to police typically negate custody.
Booking-Question Exception: Routine administrative questions (name, address, etc.) asked during booking do not require Miranda warnings unless designed to elicit incriminating information.
CPL Article 730 Evaluation: A court-ordered examination to determine whether the defendant presently understands the proceedings and can assist counsel. It does not assess sanity at the time of the offense.
Insanity / Psychiatric Defense: A substantive defense claiming the defendant lacked criminal responsibility when the crime occurred, often requiring a retrospective psychiatric assessment.
Ineffective Assistance of Counsel (IAC): Under People v. Baldi and federal/State constitutions, the defendant must show (1) counsel’s performance fell below professional norms and (2) prejudice. Strategic choices, if reasonable at the time, rarely amount to IAC.
Hinton Hearing: A hearing to determine whether courtroom closure is warranted; failing to request one generally waives public-trial claims.

Conclusion

People v. Dozier reinforces established custodial and booking doctrines but stakes out a clearer boundary in mental-health litigation: competency evaluations under CPL Article 730 are procedural tools for present-day capacity, not evidentiary tools for insanity defenses. Consequently, counsel’s tactical decision to forgo or streamline psychiatric defenses without waiting for 730 results can be both reasonable and constitutionally sound. The ruling thus furnishes both prosecutors and defense counsel with authoritative guidance on when—and when not—to intertwine competency findings with criminal-responsibility strategies. Going forward, appellate claims premised on that conflation will face a steep uphill climb.