Washington v. Coley (Majority and Dissent)
Annotate this CaseThe issue this case presented to the Supreme Court centered on the proper assignment of the burden of proof at a pretrial competency hearing following treatment designed to restore competency. The trial court placed the burden on respondent Blayne Coley to prove his incompetence. The Court of Appeals reversed, holding that the burden rested with the State to prove restoration of competency and that the trial court's mistake created structural error. Upon review of the matter, the Supreme Court reversed the Court of Appeals and held that the relevant statute, interpreted by its language, the context of the provision, the statutory scheme as a whole, and related provisions, placed the burden on the party contesting competency where, after an evaluation ordered under RCW 10.77.060, the individual has been evaluated as competent. Furthermore, the Court held that the trial court did not abuse its discretion by declining to rule on Coley's requests to proceed prose pending a competency determination, and that Coley's request after he was deemed competent to stand trial, and therefore eligible for self-representation, was equivocal.
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