nreyes_criminalcasebrief_010624

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Rasmussen College *

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CJE2172

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Feb 20, 2024

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CASE BRIEF - State v. Curtis, 921 N.W.2d 342 (Minn. 2018).   FACTS On March 2, 2015, Curtis inappropriately touched a disabled person in violation of Minn. Stat. § 609.345, subd. 1(d) (2018) and engaging in criminal sexual conduct in the fourth degree, as this statute prohibits sexual contact with a person who "the actor knows or has reason to know . . . is mentally impaired, mentally incapacitated, or physically helpless." The defense, for its part, alleges that Curtis has a mental illness, so he was not mentally stable at the time he committed the crime. Two different doctors, Dr. Stevens and Dr. Gerald Henkel- Johnson, were asked to conduct studies to determine whether Curtis was mentally competent or incompetent to proceed to trial. Dr. Stevens concluded that Curtis was exaggerating his symptoms and that he was capable. In a first study, Dr. Henkel-Johnson said that although Curtis "presents with quite a mixed symptom picture," he could proceed and suggested to his attorney that instead of asking open-ended questions, it would be more effective to ask him closed questions at his deposition. In a second study, Dr. Henkel-Johnson diagnosed Curtis as incompetent to proceed to trial. Ultimately, the court decided that Curtis was competent and found him guilty. Curtis appealed the dismissal because the state refused to comply with State v. Ganpat, 732 N.W.2d 232, which requires a burden of proof to show incompetency.
ISSUE Is the state correct in not taking Ganpat as the referent in this case and not showing a preponderance of the evidence to find Cutis mentally competent and thus proceeding with the case? HOLDING The court should have followed the standards outlined in Ganpat and placed the burden of proof on the state, which should have shown a preponderance of evidence to find Curtis Competent. RATIONALE In the Ganpat case, the state must demonstrate that the defendant is mentally competent to proceed to trial. It is established that a defendant is incompetent to proceed to trial if (1) " 'lacks sufficient ability to consult with a reasonable degree of rational understanding with defense counsel' " or (2) " 'is mentally ill or mentally deficient to be incapable of understanding the proceedings or participating in the defense.' " State v. Ganpat, 732 N.W.2d 232. The state must show that the defendant does not meet these conditions and is mentally competent by a preponderance of the evidence. The court failed to meet this requirement because it did not assign the state the burden of proof. R. Crim. P. 20.01 does not state that the state must be given the burden of proof. The state also suggests that submitting the burden of evidence is inconsistent with State v. Mills, 562 N.W.2d 276.
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