Matter of D.C.
Nevada Supreme Court
546 P.3d 810 (2024)
- Written by Nathan Benedict, JD
Facts
D.C. (defendant), a minor, was charged with murder, attempted murder, and robbery. The state sought to try him as an adult. D.C. requested a competency hearing. Three experts examined D.C. and testified at the competency hearing. Dr. Jones-Forrester opined that D.C. was not competent to stand trial due to an intellectual disability and neurocognitive disorder, possibly fetal alcohol syndrome. Dr. Foerster did not form a conclusion regarding D.C.’s competency but stated that she suspected that he was malingering. Dr. Brown testified that D.C. was competent and criticized Dr. Jones-Forrester for evaluating D.C.’s competency by an adult standard rather than by the juvenile standard. The juvenile court found D.C. competent. In its ruling, the court noted that several of the issues about which D.C. was questioned were not relevant to juvenile court. It noted that the term “plea bargain” came from adult criminal court, that the distinction between a felony and a misdemeanor had minimal significance in juvenile court, and that juvenile court did not have jury trials. Therefore, D.C.’s lack of understanding of those issues was not relevant to his competency. At a subsequent hearing, the juvenile court certified D.C. to be tried as an adult. D.C. appealed both the competency determination and the certification.
Rule of Law
Issue
Holding and Reasoning (Pickering, J.)
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