## Facts

- A delinquency petition alleged that D.D.N., age 15, committed first-degree attempted burglary in Hennepin County.
- The juvenile court ordered a 35-day residential evaluation due to concerns about D.D.N.’s competency.
- Testing showed significant cognitive and verbal limitations, including unusually low verbal IQ and deficits in memory, reasoning, and vocabulary.
- The state’s psychologist and a treatment-center case manager testified D.D.N. understood the roles of courtroom participants, the nature of the charge and proceedings, and his attorney’s function.
- Evidence showed D.D.N. remembered receiving and invoking Miranda rights and had participated in a prior plea decision.
- The defense expert highlighted serious limitations but conceded D.D.N. knew right from wrong and had some ability to understand the process and assist counsel.

## Issues

1. Whether the competency standard for a juvenile in a delinquency proceeding is the same as the adult competency standard.
2. Whether the juvenile court erred in finding D.D.N. competent to proceed despite substantial cognitive limitations.

## Decision

- The court held the competency standard for juveniles is no less than the standard applied to adults.
- The court independently reviewed the record and concluded the evidence supported the competency determination.
- The court affirmed the pretrial finding of competency and the resulting delinquency adjudication and disposition.

## Legal Principles

- Competency requires a rational and factual understanding of the proceedings and a present ability to consult with counsel with a reasonable degree of rational understanding.
- Juvenile delinquency proceedings require the same level of competency as adult trial or sentencing proceedings.
- On appeal, courts independently review whether the evidence reasonably supports inferences about competency, while recognizing the trial court’s superior ability to observe the child and witnesses.
- A person may be competent despite limited, specific areas of difficulty, so long as the person can understand the proceedings and assist counsel; identified limitations may require monitoring during the proceedings.

## Conclusion

The court affirmed a juvenile competency finding, ruling that Minnesota applies the adult competency standard in delinquency cases and that substantial cognitive limitations do not bar prosecution where the child can understand the proceedings and consult with counsel.


In re Welfare of D.D.N., 582 N.W.2d 278 (Minn. Ct. App. 1998)