1. Mental Health--Criminal Offenses--Competency To Stand Trial
A criminal defendant has a constitutional right not to be tried if he is legally incompetent.
2. Mental Health--Criminal Offenses--Competency To Stand Trial
The mental competence of an accused must be regarded as an absolute basic condition of a fair trial.
3. Mental Health--Criminal Offenses--Competency To Stand Trial
the test of whether a criminal defendant is competent to stand trial is whether he has a sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding--and whether he has a rational as well as a factual understanding of the proceedings against him.
4. Mental Health--Criminal Offenses--Competency To Stand Trial
Where trial court ruled that murder defendant was competent to stand trial, it was held on appeal as a matter of law that the State had not met its burden of proving by a preponderance of the evidence that the defendant had the requisite ability to consult with his lawyer and the requisite understanding of the proceedings against him to be determined competent to stand trial.
5. Mental Health--Criminal Offenses--Competency To Stand Trial
The trial court erred in finding the defendant competent to stand trial by focusing narrowly on the defendant's factual understanding capabilities, since for a defendant to be competent to stand trial, a mere factual understanding of the proceedings is not enough; the defendant must also have a rational understanding of the nature of the charges brought against him and the purpose of the trial proceedings based upon those charges, as well as the ability to communicate meaningfully with his lawyer so as to be able to make informed choices regarding trial strategy.
6. Mental Health--Criminal Offenses--Competency To Stand Trial
While the presence of mental illness is certainly not conclusive of incompetence, the nature and severity of a defendant's illness, as well as the effect of appropriate medication, should be a significant consideration in judging competence.
A defendant cannot be competent for some trial proceeding purposes and incompetent for others; he is either competent or he is incompetent.
8. Mental Health--Criminal Offenses--Competency To Stand Trial
Trial court erred as a matter of law in ruling that criminal defendant was competent to stand trial, where it focused too narrowly upon the defendant's factual understanding capabilities and gave inadequate consideration to the nature and severity of defendant's mental illness.
A finding that a defendant is competent to stand trial requires a finding, as a matter of law, that he is also competent to enter a plea of not guilty by reason of insanity.
The opinion of the court was delivered by: Douglas
The Superior Court (Pappagianis, J.) transferred the following questions, with rulings, to this court pursuant to RSA 491:17 and Supreme Court Rule 8 : (1) whether the record in the case thus far supports the court's ruling that the defendant is competent to stand trial; and (2) whether a finding that a defendant is competent to stand trial requires a finding, as a matter of law, that he is also competent to enter a plea of not guilty by reason of insanity.
The court also transferred a number of questions without rulings relating to the ability of the guardian ad litem to plead for the defendant and the need for another competency hearing after the decision of this court. SUP. CT. R. 9. For the reasons which follow, we answer the first question in the negative and reverse the court's ruling that the defendant was competent to stand trial. We answer the second question in the affirmative and affirm the court's ruling that the defendant was incompetent to enter a plea. Because of our Disposition of the questions transferred with rulings, we will not address the questions transferred without rulings.
The defendant, Dana Champagne, was indicted on October 4, 1983, for second degree murder in the stabbing deaths of his parents. On that date he was admitted to the forensic unit at the New Hampshire Hospital for stabilization of his mental condition.
Between 1973 and 1983 the defendant had been admitted to psychiatric hospitals on seven occasions. He is psychotic, suffering from paranoid schizophrenia, and has been operating under the same active delusional system for ten or twelve years. These delusions revolve around a theory that there are people, whom he calls "flesh eaters", who catch and sell and eat other people. It was on the belief that his parents were among this group, and that God had ordered him to do so, that the defendant killed them. The defendant sees the "mark of the beast" on the Pope, President Reagan and others.
On March 13, 1984, a hearing was held before the Court (Flynn, J.) to determine the defendant's competency to stand trial. Dr. Edward L. Rowan, testifying for the State, gave the opinion that, while he believed the defendant was competent when he interviewed him on December 15, 1983, he was not sure whether the defendant currently had a rational understanding of the proceedings. Dr. Paul Emery, a forensic psychiatrist, testified that, at the State's request, he had examined the defendant. Although he had concluded on February 2, 1984, that the defendant was competent, he now believed the defendant was incompetent because he was not rational. The court found the defendant incompetent to stand trial and ordered him committed to New Hampshire Hospital for the purpose of treatment directed towards his becoming competent. The court also suspended the criminal proceedings until May of 1984, to which the defendant excepted and asserted his right to a speedy trial.
A second competency hearing was held on May 15, 1984, before Dalianis, J. Dr. Rowan testified that he believed the defendant was now competent to stand trial. He based this opinion largely on the fact that the defendant was currently taking antipsychotic medication administered by the hospital to enable him to control his own thoughts. Also greatly influencing Dr. Rowan's opinion were recent statements by the defendant to the effect that, if he were to be found incompetent, he would be committed to the Brown Building at the New Hampshire Hospital, where civil committees are housed and where security is less restrictive than at the forensic unit.
Dr. Emery testified on behalf of the defense, although he had been retained in the case by the State. He had spoken with the defendant for thirty-five minutes the previous night and concluded that his mental condition was the same as in March and that he remained incompetent. Although agreeing with Dr. Rowan that the defendant has, at times, a limited factual understanding of the proceedings, Dr. Emery believed the defendant lacked a rational understanding due to his active delusional system. The defendant, he testified, is liable at any time to retract his apparent factual understanding and, under his delusions, change his view of the actual nature of the proceedings. This, according to Dr. Emery, also prevents the defendant from rationally consulting with his attorney, as does the looseness of his thinking. Dr. Emery based these Conclusions on the length of his interview with the defendant, stating that one might rely on the defendant's first answer to any given question "but as the interview progressed and at sufficient length, you get comments that are the opposite because there is no rational basis." Although Dr. Emery admitted that the defendant may have an interest, as most people would, in going to the Brown Building rather than being criminally committed, he would not agree that the defendant manipulates his psychosis to further that intent. On May 17, 1984, Dalianis, J. rule that the defendant was competent to stand trial.
On May 31, 1984, the third and final hearing on the defendant's competency was held before Pappagianis, J. Dr. Rowan and Dr. Emery again testified for the State and for the defendant, respectively. Their testimony remained largely unchanged from the previous hearing. Dr. Rowan again stated that in his opinion the defendant was competent. He based this opinion on a fifteen-minute conversation with the defendant that morning, during ...