State of Minnesota v. Jessica Clara Aydt

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-1973
A25-1977

State of Minnesota,
Respondent,

vs.

Jessica Clara Aydt,
Appellant.

Filed October 12, 2026
Reversed and remanded
Slieter, Judge*

McLeod County District Court
File No. 43-CR-23-1634 43-CR-23-800, 43-CR-18-150

Keith Ellison, Attorney General, St. Paul, Minnesota; and

Ryan Hansch, McLeod County Attorney, Steven Ott, Assistant County Attorney, Glencoe,
Minnesota (for respondent)

Cathryn Middlebrook, Chief Appellate Public Defender, Leah C. Graf, Assistant Public
Defender, St. Paul, Minnesota (for appellant)

Considered and decided by Smith, Tracy M., Presiding Judge; Bentley, Judge; and
Slieter, Judge.

* Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.

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NONPRECEDENTIAL OPINION
SLIETER, Judge
In this consolidated appeal from two final judgments of conviction for fifth-degree
controlled-substance possession, appellant claims the convictions must be reversed and the
matter remanded to allow her to withdraw her guilty pleas because she entered them while
incompetent and, alternatively, they were inaccurate. Because we agree that the record
contains insufficient evidence that appellant was restored to competency after she was
presumed incompetent, we reverse and remand.
FACTS
Respondent State of Minnesota charged appellant Jessica Clara Aydt with one count
of third-degree controlled-substance possession for an offense that allegedly occurred on
June 4, 2023.
At a hearing just over a week after the offense, the district court expressed concerns
about Aydt’s competency. The following week, the parties appeared for another hearing
and the district court ordered a competency evaluation under Minnesota Rule of Criminal
Procedure 20.01. Two weeks later, at a third hearing, the district court explained its reason
for ordering the evaluation, stating that it had made the decision “after interacting with Ms.
Aydt through several court hearings over a relatively short period of time in which Ms.
Aydt appeared to the court to be substantially unable to understand what I was saying about
her rights . . . and other concerns.” The district court reiterated that Aydt “appeared utterly
unable to assimilate the information that I was conveying to her and that, after several

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hearings, raised enough concern by the court that I determined we needed a Rule 20
determination before we could proceed further on the merits of her case.”
While out of custody, Aydt was arrested for new offenses that allegedly occurred
on November 6, 2023, and charged with fifth-degree controlled-substance possession and
obstruction of legal process. At a bail hearing for those offenses, the district court again
ordered Aydt to complete a Rule 20 evaluation. In January 2024, the evaluator assigned to
complete Aydt’s Rule 20 evaluation filed a letter stating that he had interviewed Aydt less
than a week after her November arrest, and that he “had intended to complete that
assessment with a final interview but ha[d] not been able to locate her.” The evaluator did
not express an opinion as to Aydt’s competency, and no evaluation was ever filed. Aydt
did not appear for a scheduled hearing that month, and the district court issued a warrant
for her arrest.
Aydt was apprehended over a year later in April 2025. At her next hearing, Aydt’s
attorney asked the district court to find her competent. The attorney argued that Aydt “was
able to express theories of the case, different defenses, different options for her, whether
that’s pleading or not pleading[,] . .
. identify people in the courtroom
and . . . talk . . . about the case.” The attorney stated that he had spoken to the evaluator “a
year ago,” who “indicate[d] at that time that he was likely to find her competent,” but that
he “had some follow- up questions [for] her,” “because she was on some pretty strong
medication” at the time of the interview. The district court asked Aydt some questions ,
after which the district court told Aydt, “[Y]ou were tracking my questions, although you
veer sometimes, but you’re able to respond to my questions and you’re calm.” The state

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told the district court, “I have no difficulty going forward with the presumption that [Aydt]
is competent since there’s been no finding of incompetence.” The district court found Aydt
competent.
The state agreed to amend the third-degree controlled-substance charge and dismiss
the obstruction charge, and Aydt entered Alford1 guilty pleas to two fifth-degree controlled-
substance-possession charges, corresponding with the June and November 2023 offense
dates. The district court entered two convictions for felony fifth-degree controlled-
substance possession and sentenced Aydt to 12 months’ imprisonment for each conviction,
to run concurrently, stayed for three years. This appeal follows.
DECISION
Aydt argues that her convictions must be reversed on two grounds. First, she argues
that the district court erred when it failed to conduct procedures adequate to protect her
right not to be tried or convicted while incompetent. Second, she argues that her Alford
guilty pleas were invalid. Because we reverse on the first issue, we do not address the
second.
A defendant has a due-process right not to be convicted of a crime while
incompetent. State v. Bauer, 245 N.W.2d 848, 852 (Minn. 1976); Medina v. California, 505 U.S. 437, 439 (1992). Under the Minnesota Rules of Criminal Procedure, criminal
proceedings must be suspended when the defendant is not legally competent.

1 By entering an Alford plea, a defendant acknowledges that the state has sufficient
evidence to obtain a conviction without expressly admitting guilt.
See North Carolina v. Alford, 400 U.S. 25, 37-38 (1970); see also State v. Goulette , 258
N.W.2d 758, 760 (Minn. 1977).

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Minn. R. Crim. P. 20.01, subds. 2-3.2 A defendant is not legally competent if, due to
mental illness or cognitive impairment, they lack the ability to “(a) rationally consult with
counsel; or (b) understand the proceedings or participate in the defense.” Id. , subd. 2.
When a “defendant’s competency is disputed, Minn. R. Crim. P. 20.01, subd. 5, creates a
presumption of incompetence.” State v. Thompson, 988 N.W.2d 149, 153 (Minn. App.
2023) (quotations omitted), rev. denied (Minn. June 20, 2023).
“[T]hroughout the course of criminal proceedings a [district court] judge must be
vigilant in ensuring that the defendant is competent to stand trial and that, when a sufficient
doubt of the defendant’s competence arises, [a district court judge] must observe
procedures adequate to ensure the defendant’s competency.” Bauer, 245 N.W.2d at 854.
The party seeking the determination of competence in a contested competency proceeding
must prove competence by a “fair preponderance of the evidence.”
State v. Ganpat, 732 N.W.2d 232, 238 (Minn. 2007); Thompson, 988. N.W.2d at 157.
“[A]n individual may have periods of competence interspersed with periods of
incompetence,” therefore, the district court must determine whether a defendant is
“currently competent.” Thompson, 988. N.W.2d at 157-58.

2 We refer to the 2022 version of Rule 20. New competency statutes became effective July
1, 2023, and “apply to competency determinations initiated on or after that date.”
2022 Minn. Laws ch. 99, art. I, §§ 50, at 1046; 26-37, at 1020-37 (codified at
Minn. Stat. §§ 611.40-.51 (2022)). In response to the new statutory scheme, the supreme
court promulgated amendments to Rule 20, effective on November 1, 2024.
Order Promulgating Amendments to the Minnesota Rules of Criminal Procedure,
No. ADM10-8049 (Minn. Sep. 20, 2024). The district court initiated a competency
determination on June 21, 2023, when it ordered the initial Rule 20 examination. Thus,
the new competency statutes and amended Rule 20 do not apply here.

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Appellate courts review de novo whether a district court should have inquired
further into a defendant’s competency. State v. O’Neill, 945 N.W.2d 71, 7 8-79 (Minn.
App. 2020), rev. denied (Minn. Aug. 11, 2020). Whereas the clear-error standard of review
applies when appellate courts review a district court’s competency findings. Id. at 80.
Here, the district court decided to inquire further into Aydt’s competence by ordering a
Rule 20 evaluation. But the district court later made a finding that Aydt was competent
even though no Rule 20 evaluation was completed. Therefore, it is unclear which standard
of review applies. But we need not decide which standard of review applies because even
under the deferential clear-error standard, the district court erred.
Appellate courts “review the district court’s factual findings to determine if they are
clearly erroneous,” and, in doing so, consider “whether its competency finding is
adequately supported by the record.” Id. at 82 (quotation omitted). “[F]indings are clearly
erroneous when they are manifestly contrary to the weight of the evidence or not
reasonably supported by the evidence as a whole.” In re Civ. Commitment of Kenney, 963
N.W.2d 214, 221 (Minn. 2021) (quotation omitted). “In applying the clear-error standard,
we view the evidence in a light favorable to the findings.” Id. “We will not conclude that
a fact[-]finder clearly erred unless, on the entire evidence, we are left with a definite and
firm conviction that a mistake has been committed.” Id. (quotations omitted).
We conclude that the record contains insufficient evidence to support the district
court’s finding that Aydt was competent. The Rule 20 evaluation was never completed,
and no portion of the evaluation was filed or admitted as evidence. Aydt’s attorney stated
that he spoke with the evaluator “a year ago,” at which point the evaluator said he was

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“likely” to conclude that Aydt was competent, but this evidence bears little on Aydt’s
competency at the time of the hearing. See Thompson, 988 N.W.2d at 157-58 (requiring
proof of “current” competence). Aydt’s attorney also acknowledged that the evaluator had
said he wanted to ask Aydt “some follow-up questions” before completing the evaluation,
because she had been “on some pretty strong medication” at the time of the interview,
suggesting that the evaluator never reached a conclusion as to Aydt’s competency. The
district court also spoke with Aydt during the hearing, and although the district court
ultimately found Aydt competent, it nonetheless noted that Aydt’s responses sometimes
“veer[ed].”
The scant evidence in the record is insufficient to overcome the presumption of
Aydt’s incompetency by a preponderance of the evidence. Thus, we reverse and remand
for the district court to permit Aydt to withdraw her guilty pleas.
Reversed and remanded.