## Facts

- The State initiated delinquency proceedings in Orleans Parish juvenile court against Pate Causey, age 16, alleging armed robbery.
- Defense counsel moved to permit dual pleas of not guilty and not guilty by reason of insanity and to appoint a panel of psychiatrists for comprehensive evaluation.
- The defense sought determinations of (1) Causey’s sanity at the time of the alleged act and (2) his competency to assist counsel.
- Psychological testing had been performed; the resulting report suggested developmental/mental problems and recommended psychiatric evaluation.
- A psychiatrist later interviewed Causey without access to the psychological test results and concluded Causey was “mentally slow” and dishonest, but not mentally ill and competent to assist in his defense.
- At the motion hearing, the juvenile judge provided the psychiatrist’s report to defense counsel only minutes before argument and asked counsel to submit the competency question on that report alone.
- Counsel submitted on the report, and the juvenile court denied the insanity plea and refused further competency inquiry or broader psychiatric evaluation.
- The Louisiana Supreme Court granted review to decide whether juveniles have a due process right to raise insanity and to obtain a competency determination.

## Issues

1. Whether due process requires allowing a juvenile in delinquency proceedings to plead not guilty by reason of insanity despite the absence of an express statutory authorization.
2. Whether due process requires a juvenile court to provide a meaningful competency evaluation and determination when there is a substantial question about the juvenile’s capacity to understand proceedings and assist counsel.

## Decision

- The Louisiana Supreme Court set aside the juvenile court’s denial and remanded for further proceedings.
- The court held that due process under the Fourteenth Amendment and the Louisiana Constitution requires permitting a juvenile to plead not guilty by reason of insanity in delinquency proceedings.
- The court held that due process requires a meaningful competency inquiry when competency is put at issue; the court may not deny evaluation and a determination based on incomplete information.

## Legal Principles

- Juvenile delinquency proceedings, though civil in form, must satisfy due process requirements when they adjudicate conduct akin to criminal behavior and may result in significant restraint of liberty.
- Due process requires a juvenile be allowed to raise an insanity defense when criminal responsibility is genuinely in question, even if juvenile statutes do not expressly provide such a plea.
- Due process forbids adjudicating delinquency when the juvenile lacks sufficient present ability to understand the proceedings and consult with counsel with a reasonable degree of rational understanding.
- When facts raise a substantial question of competency, the court must provide a reasonable, informed psychiatric/psychological evaluation and a competency determination; a cursory or incomplete report cannot substitute for that inquiry.
- The timing and manner of disclosure and the denial of further evaluation may render the competency process inadequate if they prevent meaningful litigation of mental capacity.

## Conclusion

The Louisiana Supreme Court required juvenile courts to allow an insanity plea and to conduct a meaningful competency evaluation and determination when a juvenile’s mental condition raises a substantial doubt about criminal responsibility or the ability to assist counsel, and it remanded after finding the juvenile court’s summary denial inconsistent with due process.


State in Int. of Causey, 363 So. 2d 472 (La. 1978)