State v. Vannatta

The Facts/Procedural History

Charged with murder. Convicted at trial.  The trial court appointed three doctors to examine defendant and determine his competency to stand trial.  He was found competent.  Defendant appeals on the ground that he was not competent to stand trial.  Defendant was evaluated and was determined to have a normal IQ with a “well-substantiated and well-documented history of chronic mental illness.”  He apparently has tendency to tell tall tales but will be honest when pushed.  The doctor testified that he was able to lie in his own self-interest as well.  The doctor also stated he readily understood the charges against him and roles of the judge, jury, and attorney.  Another doctor agreed with these basic assertions but stated he had serious problems in “reality testing.”  He stated that he had a frontal lobe disorder.  He warned that if defendant testified at trial he would present “unreal, grandiose beliefs that could result in his being seen in a negative light.”  The third doctor agreed with the disorder claim.  But the third doctor stated “despite his fixed delusional beliefs, he has the capacity to understand the proceedings against him and he is able to assist in his own defense as demonstrated by his verbalizations and his performance on the competency screening test.”  Therefore, the third doctor found him fit for trial.  The fourth examiner, a criminal attorney did not find him to be competent for trial.


“No person who, as a result of mental disease or defect, lacks capacity to understand the proceedings against him or to assist in his own defense shall be tried, convicted, or sentenced for the commission of an offense so long as such incapacity endures.”  “The prosecution must show by preponderance of the evidence that the defendant is competence to stand trial.”

The Issue

Whether the trial court’s decision that defendant was competent to stand trial was clearly erroneous.

The Holding/Court’s Reasoning

No, decision upheld.  Some have considered IQ as an important factor to determine competence to stand trial.  Other factors include: mental capacity “to appreciate his presence in relation to time, place, and things; he understand the offense charged; he realizes there is a judge on the bench; he understands he has a lawyer.  Each expert agreed that he understood the legal system of the role of its participants.  However, there was disagreement amongst the experts as to whether he could distinguish between reality and fantasy in providing the participants of the legal system – jury included – with a consistent rendition of the facts. The trial court is best at deciding these factors and they have decided in a not clearly erroneous way that defendant was able to stand trial because they found he was able to effectively communicate with his counsel.


All three doctors agree that defendant had a factual understanding the proceedings, that his illness caused him to elaborate and lie, but their opinion varied a great deal only as to their conclusions as to his “ability to consult with his lawyer with a reasonable degree of rational understanding.  Also, the doctors examined defendant three months prior to trial; and many things about his mental state could have changed.  The trial court clearly erred in giving greater weight to the two doctors who found him competent and ignoring the responses of the other two doctors.


Insane at the time of trial “has been used to describe questions of competency, creating the impression that competency and the insanity defense are closely related.”  Insanity defense is determined at the time of the crime, while competency to stand trial is at the time of trial.  It “concerns the defendant’s ability to interact with his attorney and to understand the proceedings he faces.”  “Competency to stand trial does not necessarily require that, if the defendant chooses to testify, the defendant must present perfectly consistent testimony or be a convincing liar.  Instead, the essence of the ability to consult with an attorney with a reasonable degree of rational understanding is that the defendant must be able to confer coherently with counsel and provide necessary and relevant information to formulate a defense.”

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