The Supreme Court today concluded 6-1 that there was insufficient evidence to support a juvenile court’s finding that a 16-year-old was competent to stand trial for brandishing a deadly weapon and for vandalism. The court found that the juvenile court improperly rejected an expert’s testimony that the juvenile was incompetent. Also in the case — In re R. V. — the court held that, in a minor’s case, the minor has the burden of rebutting a presumption of competency and that, on appeal, a juvenile court’s determination in a competency proceeding is reviewed deferentially under the substantial evidence test, not de novo.
The court’s opinion, by Chief Justice Tani Cantil-Sakauye, reverses the Fourth District, Division Three, Court of Appeal. It also disapproves an opinion of the Second District, Division Seven, Court of Appeal, because it — like the Court of Appeal in this case — applied too deferential a substantial evidence test. Justice Ming Chin dissents, but only on the application of the law to the facts of this particular case; he finds the evidence is sufficient to support the juvenile court’s competency determination.