Rather, our precedent holds that when an appellant raises as error the trial court's failure to hold a mandatory hearing on competency, the trial court must conduct a post-conviction competency hearing. See Beach v. State , 351 Ga. App. 237, 242-243 (2) (b), 830 S.E.2d 565 (2019) (trial court erred by failing to conduct a hearing to determine defendant's mental competency to stand trial within 45 days of receiving the DBHDD evaluation, such error was not corrected by issuing an order nunc pro tunc after "briefly touch[ing]" on defendant's competency hearing during a Faretta hearing, and a remand was required for the trial court to conduct a post-conviction hearing on the issue of defendant's competency at the time of trial). See also Crawford , 355 Ga. App. at 403-04, 844 S.E.2d 294 (remanding the case to conduct the competency hearing mandated by OCGA § 17-7-130 (d) (1) when trial court failed to make any determination about competency before or after trial and trial counsel testified that defendant could not communicate with him in complete sentences or otherwise).
Additionally, nothing in the record would have triggered the trial court's sua sponte obligation to inquire into Riley's competency. See OCGA § 17-7-129 (a) (the trial court has a duty to sua sponte inquire into a defendant's competency where it has information that raises a bona fide question of competency); see also Beach v. State , 351 Ga. App. 237, 241-242 (2) (b), 830 S.E.2d 565 (2019). Whether a competency evaluation is warranted depends on
This should have been completed by the court prior to ... proceeding to trial." Beach v. State , 351 Ga. App. 237, 242-243 (2), 830 S.E.2d 565 (2019). OCGA § 17-7-130 (c), which is not applicable in this case, was found to be unconstitutional as applied in McGouirk v. State , 303 Ga. 881, 815 S.E.2d 825 (2018).
(a) Because Holt did not object to the State's introduction of good character evidence about the victim, we review the trial court's decision for plain error. See Cade v. State , 351 Ga. App. 637, 649 (4), 832 S.E.2d 453 (2019) (appellate review of evidentiary rulings without objection "are conducted for plain error affecting the [a]ppellant's substantial rights under OCGA § 24-1-103 (d)"); see also Beach v. State , 351 Ga. App. 237, 243 (3) (b), 830 S.E.2d 565 (2019).To show plain error, [Holt] must point to an error that was not affirmatively waived, the error must have been clear and not open to reasonable dispute, the error must have affected his substantial rights, and the error must have seriously affected the fairness, integrity[,] or public reputation of judicial proceedings.