In the Interest of: SWM v. The State of Wyoming
299 P.3d 673
Wyo.2013Background
- Interlocutory appeal by SWM challenging juvenile court’s competency determination.
- SWM was 12 at time of alleged delinquent acts; petition filed Dec 23, 2011.
- Juvenile court ordered competency evaluation under Wyo. Stat. § 14-6-219 and requested compliance with § 7-11-303.
- Psychologist concluded SWM not competent to proceed under § 7-11-303, but court disregarded that portion and treated the case under juvenile act alone.
- Juvenile court ultimately found SWM competent to proceed, but SWM argued due process rights were violated by improper standards.
- Wyoming Supreme Court reversed, holding criminal-competency standards apply to juvenile adjudication, applied with juvenile norms, and remanded for proper proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether due process requires applying § 7-11-303 standards to juvenile competency. | SWM: apply criminal standards to juvenile competency. | State: juvenile proceedings use § 14-6-219; § 7-11-303 unnecessary. | Apply § 7-11-302/303 with juvenile norms; not sufficient to rely on § 14-6-219 alone. |
| Whether the juvenile court erred by discarding the § 7-11-303 evaluation. | SWM: the evaluation under § 7-11-303 is essential for due process. | State: § 7-11-303 portions irrelevant in juvenile context. | Correct standards must be used; disregard of § 7-11-303 violated due process. |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (United States Supreme Court 1960) (defines competence to stand trial; present abilities to understand and participate)
- In re Gault, 387 U.S. 1 (United States Supreme Court 1967) (juveniles have due process rights; not all criminal rights automatically extend)
- In re ALJ, 836 P.2d 307 (Wyoming 1992) (recognizes adjudicative vs dispositional phases; rights vary by phase; apply broadly to juveniles)
- In re W.A.F., 573 A.2d 1264 (D.C. 1990) (juvenile rights; competency evaluated with totality of circumstances)
- In Carey, 615 N.W.2d 742 (Mich. App. 2000) (use adult competency standards in absence of juvenile-specific rules; apply juvenile norms)
- In re Bailey, 782 N.E.2d 1177 (Ohio App. 2002) (adult-standard competency used for juveniles with juvenile-norm consideration)