Matter of Welfare of D.D.N.

582 N.W.2d 278 (1998)

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Matter of Welfare of D.D.N.

Minnesota Court of Appeals
582 N.W.2d 278 (1998)

Facts

In 1997, 15-year-old D.D.N. (defendant) was charged with first-degree attempted burglary in juvenile court by a prosecuting attorney (plaintiff). The juvenile court was concerned about whether D.D.N. was competent to stand trial, so the court ordered D.D.N.’s competency to be evaluated at a treatment center for 35 days. The center tested D.D.N.’s IQ, which was low average in relation to performance and was intellectually deficient in relation to verbal skills. D.D.N. had limitations with verbal memory, reasoning, and vocabulary. D.D.N.’s verbal IQ score was so low that out of 2,500 juveniles of his age, 2,490 would have had a higher score than D.D.N. At the competency hearing, despite D.D.N.’s low scores, the case manager from the treatment center and a licensed psychologist testified that D.D.N. was competent for trial. The psychologist testified that when questioned, D.D.N. demonstrated an understanding of the roles of those involved in the judicial process, such as his attorney. The psychologist testified that D.D.N. understood what his attorney communicated, understood the nature of the hearings and the charges, and recalled being notified of his Miranda rights and his decision not to talk to law enforcement without his attorney. The psychologist also testified that D.D.N. shared his recollection about being involved in the decision to take a plea in a prior court case. Although a psychologist who testified for the defense stressed D.D.N.’s cognitive limitations, this psychologist acknowledged that D.D.N. did know right from wrong, had some limited knowledge of the judicial process, and had the ability to participate in defending his case. After the hearing, the juvenile court held that D.D.N. was competent to stand trial. At trial, D.D.N. was adjudicated delinquent and placed in a treatment center for juveniles. D.D.N. appealed.

Rule of Law

Issue

Holding and Reasoning (Crippen, J.)

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