66 A.3d 568
Me.2013Background
- Nickerson was convicted of assault and refusing to submit to arrest after a jury-waived trial in Waterville District Court.
- The trial court found Nickerson competent to stand trial based on a competency hearing, seven days before the trial.
- Nickerson challenged the competency ruling, arguing the court erred in finding him competent and in not re-evaluating competency during trial.
- Evidence showed Nickerson, while not medicated and able to assist counsel, testified about the arrest and charges and stated he wished to proceed to trial.
- The evaluator opined Nickerson likely suffered from a mental illness impairing organized thinking and trial-competence; the court credited Nickerson’s testimony and his attorney’s view of competence.
- On appeal, the Maine Supreme Judicial Court affirmed the competency finding, holding there was sufficient evidence to support competence and that trial-time reconsideration was not required given absence of demonstrated doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Nickerson competent to stand trial? | Nickerson contends he was not competent. | Nickerson argues the court should have deemed him incompetent. | Yes; the court properly found competence by preponderance of evidence. |
| Did the court err by not reconsidering Nickerson’s competency during trial? | Nickerson asserts renewed doubt required reevaluation. | No doubt emerged; presumption of competence applied. | No error; implicit competency remained adequate. |
Key Cases Cited
- Haraden v. State, 2011 ME 113 (Me. 2011) (defines standard for competency to stand trial)
- Dusky v. United States, 362 U.S. 402 (U.S. Supreme Court 1960) (core framework for competency)
- State v. Comer, 584 A.2d 638 (Me. 1990) (trial court may implicitly assess competence)
- State v. Murphy, 2010 ME 140 (Me. 2010) (competence can coexist with disruption)
- Ledger v. State, 444 A.2d 404 (Me. 1982) (court may credit defendant’s testimony over experts)
- Cumming, 634 A.2d 953 (Me. 1993) (court may find competence despite contrary uncontradicted expert testimony)