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08/16/85 STATE NEW HAMPSHIRE v. DANA CHAMPAGNE

August 16, 1985

THE STATE OF NEW HAMPSHIRE
v.
DANA CHAMPAGNE



SYLLABUS BY THE COURT

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.

7. --Defenses--Insanity

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.

9. --Defenses--Insanity

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 ...


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