197 A.3d 1083
Me.2018Background
- Travis R. Gerrier was charged in 2015 with gross sexual assault (Class A), unlawful sexual contact (Class B), and furnishing liquor to a minor (Class D); he was indicted in September 2016.
- Gerrier has long-standing mental-health issues, limited cognitive and intellectual abilities, and underwent multiple evaluations (psychological, psychosexual, neuropsychological, and competency).
- A competency hearing was held; the court (Mullen, J.) reviewed the expert reports and testimony and found Gerrier competent to stand trial.
- Gerrier entered conditional guilty pleas preserving his right to appeal the competency ruling (and a suppression ruling he also challenged).
- The court sentenced Gerrier; he appealed, arguing the competency determination was erroneous. The Supreme Judicial Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper burden and evidentiary standard for pretrial competency determinations | The State contended competency is presumed and, if challenged, the party seeking incompetence must carry the burden; preponderance of evidence is appropriate | Gerrier argued the court erred in its competency determination (implicitly contesting either application of burden/standard or the factual conclusion) | Court held presumption of competency applies; burden to prove incompetence is on party challenging it; standard is preponderance of the evidence |
| Whether the trial court clearly erred in finding Gerrier competent to stand trial | State argued the record and expert testimony supported the court’s finding that Gerrier could understand charges, consequences, and cooperate with counsel | Gerrier argued his intellectual disability, autism spectrum disorder, and mood issues impaired trial competence | Court found competent: record showed Gerrier understood nature and consequences of charges, could distinguish plea options, had basic factual understanding and ability to cooperate with counsel; no clear error |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (U.S. 1960) (basic constitutional standard for competence to stand trial)
- Medina v. California, 505 U.S. 437 (U.S. 1992) (upholding preponderance standard for proving incompetence)
- Cooper v. Oklahoma, 517 U.S. 348 (U.S. 1996) (struck down clear-and-convincing standard as constitutionally unacceptable)
- Haraden v. State, 32 A.3d 448 (Me. 2011) (factors a court may consider in assessing ability to assist counsel)
- Lewis v. State, 584 A.2d 622 (Me. 1990) (competency determination is factual and reviewed for clear error)