State v. Chukwu, 230 N.C.App. 553, 749 S.E.2d 910 (Nov. 19, 2013)

The court rejected the defendant’s argument that his due process rights were violated when the trial court failed to sua sponte conduct a second competency hearing. The court held that the record demonstrated the defendant’s competency, that there was no evidence that his competency was temporal in nature, and that the trial court did not err by failing to sua sponte conduct another competency hearing. It further found that the trial court’s findings were supported by competent evidence.