State v. Matharu
2017 Ohio 8251
| Ohio Ct. App. | 2017Background
- In Oct. 2013 Matharu drove left of center, collided with Amanda Looman; Looman later died; Matharu's BAC was over twice the legal limit and he was driving on a suspended license.
- Matharu was indicted (May 22, 2014) on four counts of aggravated vehicular homicide and pleaded not guilty; suppression motion was denied after hearing.
- On Oct. 19–20, 2015 Matharu raised competency concerns and filed a pleading asserting insanity and suggesting incompetency; he had been in a coma and suffered a brain hemorrhage after the crash and reported short-term memory loss and amnesia for the collision.
- At the Oct. 20 competency hearing Matharu testified coherently, acknowledged he could take notes, remembered counsel and prior meetings, and understood the impending trial.
- The trial court declined to order a forensic competency evaluation, held a competency hearing within the statutory period, found Matharu competent, then conducted a Crim.R. 11 colloquy and accepted his no-contest plea to one count; he was sentenced to seven years.
- On appeal Matharu argued the court erred by not ordering a competency evaluation and by treating short-term memory loss as irrelevant to competency.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court abused its discretion by refusing to order a forensic competency evaluation after defendant raised incompetency concerns | State: Court acted within discretion; amnesia alone and the record did not raise a genuine question of incompetency | Matharu: Short-term memory loss and amnesia for the crash raised a genuine question of competency and required an evaluation; court wrongly stated short-term memory is not a competency component | Court affirmed: no abuse of discretion; defendant’s testimony did not raise a genuine question of competency and amnesia/limited short-term memory did not, on this record, require an evaluation |
Key Cases Cited
- State v. Brooks, 25 Ohio St.3d 144 (amnesia alone does not establish incompetency)
- State v. Berry, 72 Ohio St.3d 354 (due-process right forbids trying a legally incompetent defendant; competency standard explained)
- Dusky v. United States, 362 U.S. 402 (competency standard: ability to consult with counsel with rational understanding and to understand proceedings)
- State v. Neyland, 139 Ohio St.3d 353 (quoting Dusky and discussing competency inquiry)