STATE v. JUAN L., SC 18295

Juvenile Matters at Waterbury


      Juveniles; Delinquency; Whether § 54-56d Applies to a Juvenile Deemed Incompetent to Stand Trial.  Juan L. was fourteen when he was arrested on charges of sexual assault in the third degree, risk of injury to a minor and unlawful restraint in the first degree in connection with allegations that he engaged in non-consensual sexual contact with an eight year old boy.  Following a competency examination, the trial court found that Juan was not competent to stand trial because he was unable to understand the proceedings against him or assist in his own defense and that there was no substantial probability that he could be restored to competency.  General Statutes § 54-56d (m) provides a mechanism by which a defendant deemed not competent to stand trial can be ordered placed in the custody of the commissioner of mental health and addiction services, the commissioner of children and families or the commissioner of developmental services.  The trial court found, however, that § 54-56d does not apply in juvenile delinquency proceedings such as this one, noting that the word "juvenile" appears nowhere in the statute.  The court therefore found that it was not bound by the dictates of § 54-56d and that its decision would instead be guided by the best interest standard.  Finding that it would not be in Juan's best interest to proceed with the delinquency proceedings, the court ordered the case dismissed.  The state appeals, claiming that § 54-56d applies in juvenile proceedings and therefore that the trial court improperly dismissed the case without considering whether Juan should be committed to the custody of one of the agencies enumerated in that statute.  The state notes that § 54-56d refers repeatedly to a "defendant," and argues that the plain meaning of that term encompasses juveniles charged with crimes.  The state also claims that, because juveniles have the same constitutional rights as adults when competency is at issue, the legislature clearly intended to make § 54-56d's procedures available to both juveniles and adults.  Finally, the state contends that § 54-56d has routinely been applied in juvenile matters and that, even if that statute was not intended to apply to juveniles, the trial court should have looked to the statute's provisions for guidance in dealing with a juvenile adjudicated incompetent and unlikely to be restored to competency.