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Minnesota Supreme Court Clarifies That State Has Burden to Prove Competency to Stand Trial

by Dale Chappell

The State and not the defendant has the burden to prove that a defendant is competent to stand trial, the Supreme Court of Minnesota held, clarifying the rule on the issue of determining competency to stand trial.

After two doctors evaluated Edwin Curtis when defense counsel raised the issue that Curtis was not competent to stand trial, one said he was, the other said he was not. Even the one that said he was, could not say for sure if he was competent. After the competency hearing, the district court judge ruled that he was, saying, “I believe the assumption is unless a person exhibits incompetency, that the Court would view him as competent.”

The court cited to the first doctor’s opinion and concluded that “there is no evidence, based on his examination, the Defendant is incompetent.”

Curtis was convicted after a bench trial, and he appealed the court’s competency ruling.

The court of appeals held that competency should be determined based on the greater weight of the evidence without regard to burden of proof, ignoring that the Minnesota Supreme Court held, in State v. Ganpat, 732 N.W.2d 232 (Minn. 2007), that the State bears the burden of proving a defendant’s competence by a preponderance of the evidence. The Minnesota Supreme Court granted Curtis’ petition for review.

In Ganpat, the Supreme Court held that “the State must show the defendant’s competence by a fair preponderance of the evidence.”

However, under Minnesota Criminal Rule of Procedure 20.01(3)(6), if the court at the competency hearing “finds by a greater weight of the evidence that the defendant is competent, the court shall enter an order finding that the defendant is competent. Otherwise, the court shall enter an order finding that the defendant is incompetent.”

The court of appeals concluded that this rule allowed it to ignore Ganpat.

But the Supreme Court highlighted the last sentence, that a person questionably competent is presumed to be incompetent until proven otherwise. This, the Court said, places the burden of proof on the State. The rule creates a “presumption of incompetence,” it instructed.

The Court also pointed out that the U.S. Supreme Court recognized that “there is no settled tradition on the proper allocation of the burden of proof in a proceeding to determine competence.” Medina v. California, 505 U.S. 437, 446 (1992). While some states have ruled one way and some the other, “we answered the question in Minnesota in Ganpat when we said that the State has the burden of proof.”

Because the court of appeals was bound by the Minnesota Supreme Court’s ruling in Ganpat, it erred when it ignored that binding precedent, the Court explained.

Accordingly, the Supreme Court remanded to the district court for a determination on Curtis’ competency with the burden of proof on the State. See: State v. Curtis, 921 N.W.2d 342 (Minn. 2018). 

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