State v. Janto

In State v. Janto, 92 Hawai'i 19, 29, 986 P.2d 306, 316 (1999), the Hawai'i Supreme Court concluded that the trial court's determination of competence: (1) is "primarily a matter for the professional determination of the examiners appointed by the trial court in accordance with HRS Chapter 704"; (2) "relies upon the trial court's assessment of the testimony of expert witnesses and its observational assessment of the defendant"; and (3) is reviewed on appeal under the abuse of discretion standard of review. The Hawai'i Supreme Court held that: Hawaii Revised Statutes (HRS) 704-403 (1993) provides that "no person who as a result of a physical or mental disease, disorder, or defect lacks capacity to understand the proceedings against the person or to assist in the person's own defense shall be tried, convicted, or sentenced for the commission of an offense so long as such incapacity endures." This is the statutorily mandated standard for determining competence of a criminal defendant to stand trial. There is no need for an appellate court to engage in de novo review of the legal standard utilized by the trial court, where there is only one standard to be applied. We overrule Soares and hold that the trial court's determination that a defendant is competent to stand trial will be reviewed under an abuse of discretion standard. (State v. Janto, 92 Hawai'i 19, 28-9, 986 P.2d 306, 315-16)