In the Interest of J.K., Minor Child, J.K., Minor Child
2015 Iowa App. LEXIS 1241
| Iowa Ct. App. | 2015Background
- J.K., a juvenile with a history of behavioral problems and multiple delinquency referrals, faced several delinquency petitions alleging weapons offenses, interference with official acts, trespass, burglary, theft, and harassment.
- At age 13 his attorney requested a court-ordered competency evaluation; Dr. Stephanie Bruss evaluated J.K. and concluded he was not competent to stand trial (lacked rational understanding and could not assist counsel).
- The juvenile court held a competency hearing where Dr. Bruss testified; the State presented two witnesses who observed J.K. functioning adequately in court and treatment settings.
- The juvenile court found the presumption of competency unrebutted, gave less weight to Dr. Bruss’s report because of her inexperience, policy commentary, incomplete records review, and J.K.’s poor cooperation during evaluation, and ordered proceedings to continue.
- J.K. appealed, arguing (1) the presumption of competency when applied to a young juvenile violated procedural due process, and (2) he met his burden to prove incompetency by a preponderance of the evidence. The Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1. Whether presuming juvenile competency and placing burden on juvenile violates due process | J.K.: presumption is fundamentally unfair for young children (as-applied) and conflicts with traditions presuming incapacity for young children | State: presumption is consistent with due process; any policy changes belong to legislature | Court: No due process violation; presumption permissible and not fundamentally unfair in this context |
| 2. Whether J.K. proved incompetency by a preponderance of the evidence | J.K.: Dr. Bruss’s evaluation shows immaturity, borderline cognition, trauma, and impulsivity prevent assisting counsel with rational understanding | State: Dr. Bruss’s opinion is undermined by her limited experience, policy advocacy in report, failure to review records, J.K.’s poor cooperation, and contrary testimony showing functional courtroom behavior | Court: J.K. failed to rebut presumption; Dr. Bruss’s opinion insufficient and weight favored State evidence; competency finding affirmed |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (standard for competency: factual and rational understanding and ability to consult with counsel)
- Drope v. Missouri, 420 U.S. 162 (competency requirement linked to due process)
- Medina v. California, 505 U.S. 437 (allocating burden to defendant to prove incompetency by preponderance does not violate due process)
- Cooper v. Oklahoma, 517 U.S. 348 (rejecting heightened burden of proof for incompetency as violating due process)
- In re A.K., 825 N.W.2d 46 (Iowa Supreme Court on delinquency proceedings’ rehabilitative aim; juvenile competency framework)
- State v. Lyman, 776 N.W.2d 865 (Iowa precedent applying competency statute and presumption of competency in criminal context)
- In re Gault, 387 U.S. 1 (juveniles entitled to essentials of due process in delinquency proceedings)