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State v. Curtis

Supreme Court of Minnesota

December 19, 2018

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

          Court of Appeals Office of Appellate Courts

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

          Cathryn Middlebrook, Chief Appellate Public Defender, Michael McLaughlin, Assistant State Public Defender, Saint Paul, Minnesota, for appellant.

         SYLLABUS

         1. The court of appeals is bound by supreme court precedent.

         2. Because the State contended that the defendant was competent to stand trial on criminal charges, the State bore the burden of proving the defendant's competence.

         3. Because we cannot be certain that the district court would have reached the same competency determination had it applied the correct burden of proof, a remand to the district court is required.

         Reversed and remanded.

          OPINION

          GILDEA, CHIEF JUSTICE.

         The question presented in this case is whether the State or the defendant bears the burden of proving in a criminal case that the defendant is competent. The district court determined that appellant Edwin Thomas Curtis was mentally competent to proceed to trial. Following a stipulated-facts trial, the court convicted Curtis of fourth-degree criminal sexual conduct. On appeal, Curtis challenged the district court's competency determination, arguing that the court failed to place the burden of proof on the State as required by State v. Ganpat, 732 N.W.2d 232 (Minn. 2007). Declining to follow Ganpat, the court of appeals held that competency should be determined based on the greater weight of the evidence without regard to burden of proof. Because the court of appeals and the district court erred in failing to adhere to Ganpat and we cannot be certain the district court would have made the same competency determination had it applied the correct burden of proof, we reverse the decision of the court of appeals and remand to the district court for proceedings consistent with this opinion.

         FACTS

         The State charged Curtis with criminal sexual conduct in the fourth degree under Minn. Stat. § 609.345, subd. 1(d) (2018). This statute prohibits sexual contact with a person whom "the actor knows or has reason to know . . . is mentally impaired, mentally incapacitated, or physically helpless." The State alleged that on March 2, 2015, Curtis touched an incapacitated person's breasts and genitals through her clothing. Counsel for Curtis suggested to the district court that Curtis was not mentally competent. In response, the court ordered an evaluation of Curtis consistent with Rules 20.01and 20.02 of the Rules of Criminal Procedure.[1]

         Dr. Craig Stevens conducted the evaluation. Dr. Stevens had examined Curtis before and was aware that Curtis had been committed for mental health treatment in 2008, 2012, and 2013. Dr. Stevens acknowledged that Curtis suffered from a significant mental illness. But because Dr. Stevens believed that Curtis was malingering, Dr. Stevens concluded that it was not possible to determine Curtis's capacity to stand trial. Dr. Stevens opined that, because Curtis had not demonstrated his incompetence, Curtis was competent.

         After receiving Dr. Stevens's report, the district court held a hearing. Dr. Stevens summarized his Rule 20.01 finding at the hearing: "Basically, I - I was unable - because of [Curtis's] poor performance, and which appeared to be purposeful, I really had no information about his competency, and I believe the assumption is unless a person exhibits incompetency, that the Court would view him as competent."

         Following the hearing, the district court determined that Curtis was competent to stand trial. The court incorporated into its findings of fact Dr. Stevens's opinion that "the Court should find the Defendant to be competent as there is no evidence, based on his examination, the Defendant is incompetent." The court also referenced Dr. Stevens's conclusion that Curtis was exaggerating his symptoms. The district court's order did not cite any specific evidence that indicated Curtis had the capacity to participate in his defense, consult with counsel, or understand the proceedings. Nevertheless, citing the standard set ...


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