In a 4-3 decision, the Colorado Supreme Court on Monday upheld the denial of a competency hearing in a criminal case plagued by difficult relationships between the defendant and his attorneys.

William Arthur Lindsey defrauded investors of approximately $3 million over 13 months, and received a 2012 indictment for securities fraud and theft. It took three years for Lindsey to stand trial after a series of procedural delays and substitutions in his defense counsel.

Lindsey’s fourth and most recent attorney, David G. Tyler, filed a motion to withdraw due to “irreconcilable differences” with his client. Namely, he said Lindsey had not cooperated with him and had not provided necessary payments or information. Lindsey countered that his lawyer failed to work diligently on the case. The judge denied Tyler’s request.

Shortly before trial, Tyler filed a motion alleging Lindsey was not competent to proceed, raising many of the same concerns as in his withdrawal motion. While Lindsey initially objected to the filing before the judge, after a brief recess in the courtroom he returned and said he agreed with his lawyer.

The judge weighed all relevant factors and concluded that there was no good-faith doubt that Lindsey was “able to act and speak rationally,” and had “a reasonable degree of rational understanding in order to assist in the defense in this case.” The real issue, the judge observed, was lack of cooperation, rather than lack of competency.

Midway through the trial, the defense again attempted to halt proceedings and have Lindsey undergo a competency evaluation. The judge denied the motion and a jury subsequently found Linsey guilty. The Colorado Court of Appeals vacated the conviction after finding that the district judge should have ordered a competency evaluation.

Justice Carlos A. Samour, Jr., writing for the Supreme Court’s majority, found that the actual competency motion was “barren of specific facts supporting a good-faith doubt regarding Lindsey’s competency.” The court listed off numerous ways in which Lindsey failed to cooperate with his lawyer. Transcripts showed that Lindsey “had no difficulty understanding the proceedings, disputing Tyler’s assertions, or communicating his concerns about Tyler’s services.”

Samour concluded that if Lindsey’s argument prevailed, any lawyer with a difficult client could request a competency hearing and put trial courts’ proceedings in turmoil. The majority felt that courts have the discretion to authorize competency hearings, and allowing any such motion to proceed automatically could create a backlog that disadvantages legitimate needs for evaluation.

Justice Melissa Hart, dissenting on behalf of herself and Justices Monica M. Márquez and Richard L. Gabriel, believed that Tyler’s competency motion was proper, and the trial judge did not need to make a ruling on good-faith grounds.

“Confronted with the plain language of this statutory scheme, I do not believe it is appropriate to add a requirement – the judge’s determination that the motion to determine competency was made in good faith – that the legislature did not actually write into the law,” she argued.

The case is The People of the State of Colorado v. William Arthur Lindsey.