Cited by
Opinions in Minnesota that cite Bonga v. State, 797 N.W.2d 712.
-
State of Minnesota, Respondent,
Minn. Ct. App. 2026
Competency involves a defendant’s ability to consult with his attorney and understand the proceedings against him, while involuntariness involves external pressure or inducement.
- State of Minnesota, Respondent, Minn. Ct. App. 2026
- James Ervin Owen, petitioner, Appellant, Minn. Ct. App. 2025
- State of Minnesota v. Jeremy Jyrone White Minn. Ct. App. 2025
-
State of Minnesota v. Jeremy Jyrone White
Minn. Ct. App. 2025
ounsel to request a competency evaluation if they, “at any time before or after conviction, doubt[] the defendant’s competency to proceed.” A defendant is competent if they have “sufficient present ability to consult with [their] lawyer with a reasonable degree of rational understanding and ha[ve] a rational as well as factual understanding of the proceedings against [them].” (quotation omitted).
- State of Minnesota v. Kou Yang Minn. Ct. App. 2024
-
State of Minnesota v. Kou Yang
Minn. Ct. App. 2024
“A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.”
- State of Minnesota v. Joshua Henry Baion Cummings Minn. 2024
- State of Minnesota v. Joshua Henry Baion Cummings Minn. 2024
-
State of Minnesota, Respondent,
Minn. Ct. App. 2023
“A defendant has a due process right not to be tried [and] convicted of a criminal charge if [the defendant] is legally incompetent.” (citing Drope v. Missouri, 420 U.S. 162, 171 (1975)); -55 ( Minn. 1976) (applying Drope in Minnesota).
-
Jordan Lee Wachter, petitioner, Appellant,
Minn. Ct. App. 2023
“A defendant has a due process right not to be tried or convicted of a criminal charge if he or 9 she is legally incompetent.” (citing Drope v. Missouri, 420 U.S. 162, 171 (1975), and Pate v. Robinson, 383 U.S. 375, 378 (1966)) (other citations omitted).
-
State of Minnesota, Respondent,
Minn. Ct. App. 2023
Both the United States and Minnesota Supreme Courts recognize that “[a] defendant has a due process right not to be tried or convicted of a criminal charge if he is legally incompetent.” Curtis , d at 346 (citing Drope v. Missouri, 420 U.S. 162, 171 -72 (1975); ).
-
State of Minnesota, Respondent,
Minn. Ct. App. 2022
if the defendant due to mental illness or cognitive impairment lacks [the] ability to: (a) rationally consult with counsel; or 7 (b) understand the proceedings or participate in the defense.” Id.
-
State of Minnesota, Respondent,
Minn. Ct. App. 2022
State v. Curtis , (citing Drope v. Missouri , 420 U.S. 162, 171-72 (1975); ).
-
State of Minnesota, Appellant,
Minn. Ct. App. 2022
if the defendant due to mental illness or cognitive impairment lack s ability to: (a) rationally consult with counsel; or (b) understand the proceedings or participate in the defense.” Id.
-
State of Minnesota, Respondent,
Minn. Ct. App. 2022
“A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.” 718 (Minn. 2011).
-
State of Minnesota, Respondent,
Minn. Ct. App. 2022
Because criminal defendants have a due-process right not to be tried while incompetent, Minnesota Rule of Criminal Procedure 20.01 requires the district court to order a competency evaluation if it “doubts the defendant’s competency” at any time.
- State of Minnesota, Respondent, Minn. Ct. App. 2021
-
State of Minnesota, Respondent,
Minn. Ct. App. 2021
A defendant is competent to proceed where he “has sufficient present ability to consult with his lawyer with a reasonable degree of rational understa nding and has a rational as well as a factual understanding of the pro ceedings against him.” Bonga v. State , (quotation omitted).
-
Markhel D’John Harris-Franklin, petitioner, Appellant,
Minn. Ct. App. 2021
“A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.”
-
State of Minnesota, Respondent,
Minn. Ct. App. 2021
“[A] defendant’s irrational behavior, his demeanor at trial, and any prior medical opinion on competence to stand trial are all relevant in determinin g whether further inquiry is required.” (quoting Drope v. Missouri , 420 U.S. 162, 180, 95 S. Ct. 896, 908 (1975)).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2020
-
State of Minnesota, Respondent,
Minn. Ct. App. 2020
Conversely, a defendant is competent if he “has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding and has a rational as well as factual understanding of the proceedings against him.” (quotation omitted).
- Michael David Henderson, petitioner, Appellant, Minn. Ct. App. 2019
-
Michael Opeoluwa Adebayo, petitioner, Appellant,
Minn. Ct. App. 2019
“A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.”
- State v. Hallmark 927 N.W.2d 281 Minn. 2019
-
State v. Hallmark
927 N.W.2d 281
Minn. 2019
Bonga v. State , , 718 (Minn. 2011) (citing Drope v. Missouri , 420 U.S. 162 , 171, 95 S.Ct.
- State v. Curtis 921 N.W.2d 342 Minn. 2018
-
State v. Curtis
921 N.W.2d 342
Minn. 2018
896 , 43 L.Ed.2d 103 (1975) ; Bonga v. State , , 718 (Minn. 2011).
-
State of Minnesota, Respondent,
Minn. Ct. App. 2018
D E C I S I O N “A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.”
-
State of Minnesota, Respondent,
Minn. Ct. App. 2018
er it should have conduc ted further inquiry in to the defendant’s 1 A criminal defendant is competent to stand trial if he or she “‘has sufficient present ability to consult with his lawyer wi th a reasonable degree of rati onal understanding’ and ‘has a rational as well as factual understanding of the proceedings against him.’” (quoting Dusky v. United States , 362 U.S. 402, 402, 80 S.Ct.
-
Esteban Trevino, petitioner, Appellant,
Minn. Ct. App. 2018
7 “A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.”
-
State of Minnesota, Respondent,
Minn. Ct. App. 2018
See Bonga v. State , (recognizing a defendant’s due-process right not to be tried or convicted of a criminal charge if he is legally incompetent).
- Demiteras Al Cooper, petitioner, Appellant, Minn. Ct. App. 2018
- Brian Allen Barthel, petitioner, Appellant, Minn. Ct. App. 2017
-
State of Minnesota, Respondent,
Minn. Ct. App. 2017
3 D E C I S I O N “A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.”
- Dikken v. State 896 N.W.2d 873 Minn. 2017
- Dikken v. State 896 N.W.2d 873 Minn. 2017
- Clayton James Hanks, petitioner, Appellant, Minn. Ct. App. 2017
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- Brooks v. State 897 N.W.2d 811 Minn. Ct. App. 2017
- Brooks v. State 897 N.W.2d 811 Minn. Ct. App. 2017
- A16-1713 Minn. Ct. App. 2017
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- John Patrick Murphy, petitioner, Appellant, Minn. Ct. App. 2017
- Denis Alcivar Alvarado-Riera v. State of Minnesota Minn. Ct. App. 2017
-
Denis Alcivar Alvarado-Riera v. State of Minnesota
Minn. Ct. App. 2017
13 “A defendant has a due process right not to be tried or convicted of a criminal charge if he or she is legally incompetent.”
- State of Minnesota v. Brandon Richard Blegen Minn. Ct. App. 2016
- State of Minnesota v. Brandon Richard Blegen Minn. Ct. App. 2016