State v. Coley
326 P.3d 702
Wash.2014Background
- Defendant Blayne Coley was charged with two counts of second‑degree child rape; competency concerns arose pretrial and led to multiple evaluations at Eastern State Hospital.
- A December 2008 uncontested report led a court to find Coley competent; in April 2009 a new evaluation produced a finding of incompetency and the court ordered a 90‑day stay and treatment to restore competency.
- After treatment, the State’s expert (Dr. Grant) reported Coley was competent; the defense submitted a contrary expert report and the court held a competency hearing in June 2010.
- At that hearing the trial court placed the burden on Coley to prove incompetence by a preponderance and found him competent; the case later proceeded to retrial and conviction.
- On appeal the Court of Appeals reversed, holding the State should have borne the burden to prove restoration of competency and that the misallocation was structural error; the State sought review.
Issues
| Issue | Plaintiff's Argument (Coley) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Proper allocation of burden at a competency hearing after court‑ordered restoration treatment | Where a prior court order found defendant incompetent and ordered restoration, the presumption shifts and the State must prove restoration (i.e., State bears burden) | Chapter 10.77 RCW and precedent support placing burden on the party challenging competency (which may be the defendant); no statutory mandate shifting burden to State after a restoration order | Burden rests with the party challenging competency to prove incompetence by a preponderance; trial court did not err |
| Whether that statutory burden allocation violates due process | Mathews balancing requires State to bear burden; defendant contends due process favors State burden | Medina controls: due process does not demand a particular burden allocation; placement on challenger does not violate due process | Placing burden on challenger does not violate federal or state due process under Medina framework |
| Whether trial court erred by deferring or denying Coley’s requests to represent himself pending competency resolution | Coley contends court improperly deferred consideration of his pro se request based on perceived incompetency (citing Madsen) | Court properly deferred where competency was legitimately in doubt and ordered evaluation; only unequivocal, timely requests must be honored | Court did not abuse discretion: no timely, unequivocal request after competency was established; earlier pro se grant in 2009 was properly handled |
| Whether the misallocation (if any) was structural error requiring automatic reversal | Coley argued burden misplacement was structural and necessitated reversal | State argued statutory placement was lawful and not a structural error | Majority: no structural error because court followed statutory scheme; Court of Appeals reversed and its judgment is reversed and remanded to reinstate competency and guilt findings |
Key Cases Cited
- Medina v. California, 505 U.S. 437 (U.S. 1992) (due process does not require any particular burden allocation at competency hearings)
- State v. Hurst, 173 Wn.2d 597 (Wash. 2012) (preponderance is proper standard under chapter 10.77 and burden placement discussion)
- State v. Ortiz, 104 Wn.2d 479 (Wash. 1985) (deference to trial court competency determinations; review for abuse of discretion)
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (constitutional right to self‑representation)
- State v. Madsen, 168 Wn.2d 496 (Wash. 2010) (requirements that a request to proceed pro se be timely and unequivocal; courts must not use competency concerns as a pretext to deny a proper Faretta claim)
- Drope v. Missouri, 420 U.S. 162 (U.S. 1975) (reversal/remand required where competency errors affect trial adequacy)