State v. Thompson

Why This Case Matters

State v. Thompson addresses a fundamental question in criminal law: what happens when a defendant charged with a serious crime may not be mentally competent to stand trial? The Court of Appeals held that when a defendant is the one asserting competence in a contested proceeding under Minnesota Rule of Criminal Procedure 20.01, the defendant bears the burden of proving competence by a fair preponderance of the evidence. This decision clarified who must prove what in competency disputes — an issue that affects defendants with serious mental health conditions.

The Facts

In September 2018, the State charged Nicholas Scott Thompson with second-degree intentional murder and two counts of second-degree unintentional felony murder. The charges stemmed from the strangling death of his mother, Rebecca G. Thompson, on July 4, 2018, in Jackson, Minnesota.

Thompson had a documented history of mental health issues, including psychosis and hallucinations. Based on this history, the district court ordered a competency evaluation under Rule 20.01 to determine whether Thompson was able to understand the proceedings and assist in his own defense.

Between 2019 and 2021, the court received eight written competency reports from four different examiners. Seven of the eight reports found Thompson incompetent to stand trial. One report was inconclusive. Despite this, Thompson himself asserted that he was competent and wanted to proceed to trial. The district court found him incompetent. Thompson appealed — the third pretrial appeal on the competency question in this case.

What the Court Decided

The Court of Appeals affirmed the district court’s finding that Thompson was incompetent to stand trial. The central legal question was which party bears the burden of proof when the defendant is the one claiming competence.

The court held that under Rule 20.01, when a defendant asserts his own competence in a contested proceeding, the defendant bears the burden of proving competence by a fair preponderance of the evidence. The court reasoned that the rule places the burden on the party raising the issue — and here, Thompson was the party asserting competence against the weight of the expert evidence.

Given the overwhelming expert opinion — seven of eight reports finding Thompson incompetent — the court concluded that Thompson had not met his burden. The district court’s finding of incompetence was supported by the record and was not clearly erroneous.

What This Means for You

• Competency is about understanding, not guilt. A competency determination does not decide whether someone committed a crime. It decides whether the person can understand the court proceedings and meaningfully help their attorney with the defense.
• The burden depends on who raises the issue. If you are the one asserting that you are competent to stand trial, you bear the burden of proving it. If the State raises the issue, the burden may fall differently.
• Expert opinions carry significant weight. Courts rely heavily on reports from psychologists and psychiatrists when deciding competency. Multiple expert opinions finding incompetence are very difficult to overcome.
• Being found incompetent does not end the case. If a court finds you incompetent, the charges are not dismissed. Instead, the court may order treatment to restore competency so the case can proceed later.
• Get help from a defense attorney. If you or a family member faces a competency question in a criminal case, speak with a public defender or criminal defense attorney. These proceedings are legally and medically complicated, and experienced counsel is essential.