A murder defendant who withdraws his defense of mental disease or defect prior to trial cannot claim he was not competent to waive his Miranda rights. The defendant, under the influence of drugs, was arrested and three days later confessed to the crimes of second-degree murder and possession of a controlled substance with intent to deliver. He wrote "yes" beside each statement in the waiver-of-rights document. A police officer present at the confession said that the defendant was down from the drugs and was completely coherent. The defendant even exercised his Miranda rights during the confession by saying, "I'm wanting to shut up."

After being examined for 30 days in the state mental hospital, the defendant was found to have amphetamine-induced psychotic disorder and incompetent to assist in his own defense. After a year's stay in a hospital, he was found competent to assist his attorneys and understand the proceedings against him.

The Supreme Court of Arkansas noted, "based on the totality of the circumstances, we conclude that the trial court's determination that appellant made a knowing and intelligent waiver of his Miranda rights was not clearly erroneous.... Further, we note that appellant withdrew his defense of mental disease or defect prior to trial, thereby eliminating the question of his sanity from the issues considered at trial."