State v. CurtisAnnotate this Case
The Supreme Court reversed the court of appeals affirming the district court’s competency determination in this criminal case, holding that the court of appeals erred when it did not follow State v. Ganpat, 732 N.W. 2d 232 (Minn. 2007), and place the burden of proving that Defendant was competent on the State.
After determining that Defendant was mentally competent to proceed to trial, the district court convicted him of fourth-degree criminal sexual conduct. Defendant appealed, arguing that the district court failed to place the burden of proof on the State as required by Ganpat in determining him to be competent. In affirming, the court of appeals declined to follow Ganpat, instead ruling that competency should be determined based on the greater weight of the evidence without regard to burden of proof. The Supreme Court reversed and remanded, holding that the court of appeals and district court erred in failing to adhere to Ganpat and that it was not certain whether the district court would have made the same competency determination had it applied the correct burden of proof.