Bonga v. State, 2011 Minn. LEXIS 275

Bonga pleaded guilty to first-degree premeditated murder of Carlos San Miguel and was sentenced to life in prison after a brief plea hearing.
Bonga confessed to the killing and, soon after, attempted suicide in jail; he challenging the plea on competency grounds.
The district court accepted the guilty plea and waived reliance on a public defender, designating standby counsel and proceeding with the plea.
Bonga sought postconviction relief to withdraw the plea, arguing he was not competent to plead guilty or waive counsel.
In Bonga I, this Court reversed the postconviction court’s dismissal and remanded for reconsideration with attention to competence.
On remand, the postconviction court again denied relief, concluding there was no reason to doubt Bonga’s competency; this appeal follows seeking review of that determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court should have suspended proceedings for a competency evaluation.	Bonga argues substantial evidence of incompetence required evaluation.	State contends no sufficient doubt; proceedings properly weighed evidence.	No reversible error; court properly weighed evidence and found no need for further inquiry.
Whether suicide attempt plus demeanor necessitated further inquiry under Minn. R. Crim. P. 20.01.	Drope factors and suicide evidence mandate examination and possible postponement.	Observations during plea hearing and interactions with standby counsel negate substantial doubt.	Evidence supported keeping proceedings; competency found not in doubt under rule.
Whether the district court adequately accounted for evidence suggesting incompetence when accepting the plea.	Court failed to weigh suicide attempt and depression as undermining competence.	Court properly considered evidence and duties under 20.01; no need for further inquiry.	Court gave proper weight to evidence; no need for additional inquiry.

Drope v. Missouri, 420 U.S. 162 (1975) (factors relevant to competence; no fixed standard)
Pate v. Robinson, 383 U.S. 375 (1966) (due process and competency to stand trial)
Camacho v. State, 561 N.W.2d 160 (Minn. 1997) (competency standard; reaffirmed Drope framework)
Bauer v. State, 310 Minn. 103, 245 N.W.2d 848 (Minn. 1976) (protective duty when doubt arises regarding competence)
Bonga v. State, 765 N.W.2d 639 (Minn. 2009) (reversed dismissal and discussed competence postconviction relief)
Ganpat v. State, 732 N.W.2d 232 (Minn. 2007) (competence assessment considerations)
Shoen v. State, 648 N.W.2d 228 (Minn. 2002) (competence and procedure in criminal proceedings)