Curtis v. State
2011 Ind. LEXIS 493
| Ind. | 2011Background
- Alva Curtis, 59, with developmental disability and long-standing cognitive limitations, is charged with residential entry, battery, and criminal mischief from 2007.
- Curtis requested competency evaluations; two doctors opined dementia and lack of competency, with one stating he would never be restored.
- The trial court repeatedly denied motions to dismiss, and declined to commit Curtis to the DMHA for competency restoration.
- In 2009 Curtis moved to dismiss under Indiana Criminal Rule 4(C); the court again denied and held Curtis would never become competent, but no commitment occurred.
- Curtis sought interlocutory review; the Court of Appeals held pending charges violated due process and urged dismissal, which the Indiana Supreme Court subsequently granted transfer on.
- The Supreme Court ultimately held: (a) pending charges do not violate due process if no involuntary commitment and no finding of impossibility of restoration; (b) Curtis forfeited constitutional speedy-trial claims; (c) under Rule 4(C), the State’s delays exceeded one year and the charges must be dismissed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether delay to trial violated speedy-trial rights | Curtis | Curtis | Speedy-trial claims forfeited; relief denied on constitutional grounds |
| Whether Rule 4(C) requires dismissal | Curtis | Curtis | Curtis entitled to dismissal under Rule 4(C); charges must be dismissed |
| Whether due-process fundamental fairness requires dismissal when defendant unlikely to regain competency | Curtis | State | No fundamental-fairness violation where not involuntarily committed and no finding of permanent incapacity |
| Proper procedure for competency determinations and DMHA commitment | State | Curtis | Statutory framework governs competency and potential restoration; no commitment occurred |
Key Cases Cited
- State v. Davis, 898 N.E.2d 281 (Ind. 2008) (due process limits on holding an incompetent defendant; restoration emphasized)
- Baldwin v. State, 274 Ind. 269 (Ind. 1980) (defendant's incompetency delays count toward Rule 4(C))
- Cook v. State, 810 N.E.2d 1064 (Ind. 2004) (trial-date setting and delays attributed to defendant considerations)
- Carr v. State, 934 N.E.2d 1096 (Ind. 2010) (Rule 4(C) time limits and congestion concerns; focus on timely trial)
- Danks v. State, 733 N.E.2d 474 (Ind. 2000) (separation of speedy-trial rights under constitutional and Rule 4(C))
- Harbour v. Arelco, Inc., 678 N.E.2d 381 (Ind. 1997) (proper framing of issues on interlocutory review)