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State v. Curtis

Court of Appeals of Minnesota

January 16, 2018

State of Minnesota, Respondent,
v.
Edwin Thomas Curtis, Appellant.

         St. Louis County District Court File No. 69VI-CR-15-262

          Lori Swanson, Attorney General, St. Paul, Minnesota; and Mark Rubin, St. Louis County Attorney, Karl G. Sundquist, Assistant County Attorney, Virginia, Minnesota (for respondent)

          Cathryn Middlebrook, Chief Appellate Public Defender, Michael McLaughlin, Assistant Public Defender, St. Paul, Minnesota (for appellant)

          Considered and decided by Connolly, Presiding Judge; Schellhas, Judge; and Stauber, Judge. [*]

         SYLLABUS

         A district court determines competency under Minn. R. Crim. P. 20.01, subd. 5(f), based on the greater weight of the evidence without regard to burden of proof.

          OPINION

          SCHELLHAS, Judge

         Appellant challenges his conviction of fourth-degree criminal sexual conduct, arguing that the district court erred in determining that he was competent to participate in the proceedings because the court erroneously shifted the burden of proof from respondent to appellant. We affirm.

         FACTS

         In March 2015, respondent State of Minnesota charged appellant Edwin Curtis with fourth-degree criminal sexual conduct. The complaint alleged that Curtis touched an incapacitated woman on her breasts and genitals over her clothing at the St. Louis County Detox Center. Curtis moved for a competency examination under Minn. R. Crim. P. 20.01, and a mental examination under Minn. R. Crim. P. 20.02. The district court ordered simultaneous examinations of Curtis under Minn. R. Crim. P. 20.04. The court also ordered that Curtis be examined by Dr. Craig Stevens, who had examined Curtis in 2008 and 2012.

         Following his examination of Curtis, Dr. Stevens reported that Curtis "suffer[s] from a significant mental illness (schizoaffective disorder), " but that he "seems to be using that disorder through exaggeration to try to escape consequences for his alleged misdeeds." Dr. Stevens also reported that because of Curtis's "proclivity to exaggerate his condition it is unfortunately not possible to determine his capacity at this time." Dr. Stevens determined that "[s]ince, as this examiner understands it, an individual is viewed by the court as competent unless demonstrated to be otherwise, the only outcome from the present evaluation is that . . . Curtis has not demonstrated incompetence and thus may by default have to proceed at trial as a competent defendant."

         In July 2015, the district court conducted a contested competency hearing at which Dr. Stevens testified. The court found that "as a result of [his] examination, Dr. Stevens stated that he believes the Court should find [Curtis] to be competent as there is no evidence . . . [Curtis] is incompetent." The court determined that "the greater weight of the evidence indicates [Curtis] is competent."

         In November 2015, Dr. Gerald Henkel-Johnson examined Curtis. Dr. Henkel-Johnson reported that Curtis "does appear to have adequate understanding of the charges and proceedings against him, " but Curtis's "deficits in concentration and communication skills to assist his attorney or otherwise adequately participate in his defense are concerning." Dr. Henkel-Johnson initially found Curtis to be competent, but later supplemented his report with an addendum, stating that Curtis's difficulty in answering "open-ended" questions "may result in compromising [his] ability to assist in his defense." Dr. Henkel-Johnson determined that "[s]hould this be the case, then [Curtis] indeed is not competent to stand trial." (Emphasis added.)

         Based on Dr. Henkel-Johnson's report, Curtis moved for an order finding him incompetent under rule 20.01. The district court found that the results of the tests administered to Curtis by Dr. Henkel-Johnson "are indicative of a person attempting to produce a false result." The court concluded that despite Dr. Henkel-Johnson's belief that Curtis may be incompetent to ...


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