McLaren v. State, 407 P.3d 1200

Background

In March 2014 McLaren attacked his girlfriend after using methamphetamine and reporting hallucinations; she sustained head lacerations and bruises. He was charged with attempted second-degree murder, strangulation, two counts of aggravated assault, and kidnapping.
McLaren underwent multiple evaluations: two competency-to-proceed exams (June 2014 and Feb. 2016) and NGMI (insanity) evaluations; all examiners found him competent to proceed and concluded NGMI was not supported because any psychosis appeared self-induced by meth.
Defense counsel entered a not guilty by reason of mental illness or deficiency (NGMI) plea on McLaren’s behalf; McLaren repeatedly protested on the record that he did not want the NGMI plea and attempted to withdraw counsel or the plea.
At trial counsel pursued an NGMI defense over McLaren’s objections; the jury was instructed on NGMI, found McLaren guilty on all counts, and he received lengthy consecutive sentences.
On appeal the court held the trial court did not err in declining to order a third competency evaluation, but concluded due process was violated when counsel (and the court) persisted in asserting the NGMI plea over McLaren’s repeated, competent objections; the conviction was reversed and remanded.

Issues

Issue	Plaintiff's Argument (McLaren)	Defendant's Argument (State)	Held
1) Whether court should sua sponte order another competency evaluation	McLaren: trial conduct and outbursts showed decompensation giving reasonable cause for another evaluation	State: prior evaluations found competence; behavior was consistent with prior records, so no new cause	Court: No error — no new information justified a third competency exam
2) Whether counsel may assert NGMI over a competent defendant's objection	McLaren: he repeatedly and clearly opposed NGMI; a competent defendant has exclusive right to choose plea — due process violated	State: record insufficient to show plea was maintained against his will; counsel may make tactical decisions	Court: Held counsel (and court) violated due process by continuing NGMI over McLaren’s repeated objections; reversal required
3) Whether jury instructions on attempted second-degree murder improperly allocated burden on sudden heat of passion	McLaren: jury not instructed that State must prove absence of sudden heat of passion beyond a reasonable doubt	State: earlier precedent; but court guidance varies	Court: Instruction was incorrect under Shull/Schmuck; State must prove absence of heat of passion on retrial (instructional error, not structural)
4) Whether trial court abused discretion denying mistrial after McLaren’s courtroom outburst	McLaren: his outburst prejudiced proceedings and warranted mistrial	State: trial court managed conduct; no abuse shown	Court: Not reached (decision on NGMI dispositive)

Key Cases Cited

Marshall v. State, 385 P.3d 304 (Wyo. 2016) (substantial-evidence standard for denying additional competency evaluation; no new information means no further inquiry required)
Schaeffer v. State, 268 P.3d 1045 (Wyo. 2012) (prior competency finding and absence of new information justified declining further evaluation)
deShazer v. State, 74 P.3d 1240 (Wyo. 2003) (trial court should suspend proceedings to evaluate competency when new evidence of incapacity arises)
Schmuck v. State, 406 P.3d 286 (Wyo. 2017) (State must prove absence of sudden heat of passion beyond a reasonable doubt when defendant presents evidence of it)
Shull v. State, 388 P.3d 763 (Wyo. 2017) (treatment of sudden heat of passion in manslaughter instruction; discussed in relation to burden allocation)
Frendak v. United States, 408 A.2d 364 (D.C. Cir. 1979) (persuasive authority recognizing a competent defendant’s right to reject an insanity plea)
Bean v. State, 762 A.2d 1259 (Vt. 2000) (imposition of insanity defense over defendant’s clear objection requires reversal)
Jones v. State, 664 P.2d 1216 (Wash. 1983) (competent defendant has the constitutional right to decide pleas, including rejection of insanity plea)