State v. Coley
286 P.3d 712
Wash. Ct. App.2012Background
- Grant County case charging Blayne Coley with two counts of second degree rape of a child following competency disputes beginning in 2008.
- Eastern State Hospital found Coley not competent; court ordered competency restoration and stayed proceedings.
- Subsequent hearings produced conflicting competency assessments and contested reports from experts.
- The trial court initially found Coley competent in 2010, later ordering a June 22, 2010 competency determination.
- Coley’s defense argued the State bore the burden to prove competency; the court stated Coley bore the burden, which this opinion holds to be erroneous and structural.
- The operative order before the June 2010 competency hearing was July 16, 2009 declaring incompetence and staying proceedings, not December 9, 2008 competent finding, creating a misframing of the presumption.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Who bears the burden of proof in a competency proceeding | State contends burden unclear; error theoretical | Coley argues defendant bears burden | Burden misallocated; structural error; remand for proper burden |
| Whether misallocation of the burden is structural or harmless | State argues error is harmless since evidence was heard | Coley argues structural error | Structural error; remand required |
| Whether the operative presumption was incompetence due to a July 2009 order | State treats earlier orders as controlling | Coley emphasizes later incompetence finding | Operative presumption was incompetence; burden shifts to State |
Key Cases Cited
- Medina v. California, 505 U.S. 437 (U.S. 1992) (establishes that states may place burden on defendant for incompetence; due process concerns)
- Cooper v. Oklahoma, 517 U.S. 348 (U.S. 1996) (supports burden on defendant, with due process qualification)
- State v. Benn, 120 Wn.2d 631 (Wash. 1993) (preserves question of who bears burden in competency; precedent for burden shift later)
- Nissen v. Obde, 55 Wn.2d 527 (Wash. 1960) (remand when burden misallocated; foundational rule on burden placement)
- State v. Heddrick, 166 Wn.2d 898 (Wash. 2009) (due process and proper procedure in competency determinations)