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In re Petition for A Writ of Habeas Corpus By Snyder

Supreme Court of Kansas

July 27, 2018

In the Matter of the Petition for a Writ of Habeas Corpus by Clay Snyder.

         SYLLABUS BY THE COURT

         1. The Fourteenth Amendment prohibits the criminal prosecution of a defendant who is not competent to stand trial.

         2. Delays attributable to a defendant's incompetency to stand trial do not infringe upon his or her Sixth Amendment speedy trial rights.

         3. On the facts of this case, the petitioner was not denied due process under Jackson v. Indiana, 406 U.S. 715, 92 S.Ct. 1845, 32 L.Ed.2d 435 (1972).

          Original proceeding in habeas corpus.

          Mark J. Dinkel, public defender, argued the cause, and Ashley J. Long, assistant public defender, was with him on the briefs for petitioner.

          Kristafer R. Ailslieger, deputy solicitor general, argued the cause, and Derek Schmidt, attorney general, was with him on the brief for respondent.

          OPINION

          STEGALL, J.:

         In May 2013, the Saline County District Court first found Clay Robert Snyder not competent to stand trial because of his intellectual disability. Since then, Snyder has cycled through competency detainment and involuntary commitment at least twice. Most recently in November 2016, the district court found Snyder was still not competent to stand trial and ordered the State to initiate civil commitment proceedings against him.

         Shortly thereafter, Snyder petitioned for habeas relief, asking us to release him from confinement and dismiss his criminal charges with prejudice to remedy federal speedy trial, due process, and equal protection violations. We find no violations on the present showing and deny Snyder's petition for habeas relief.

         FACTUAL AND PROCEDURAL BACKGROUND

         On December 27, 2012, Snyder was charged with rape, aggravated criminal sodomy, and aggravated indecent liberties with a child in Saline County. A few days before the preliminary hearing was scheduled to occur, defense counsel filed a motion to determine Snyder's competency to stand trial. The district court granted the motion and ordered Snyder to undergo multiple competency evaluations.

         Each evaluation yielded the same conclusion-that Snyder was incompetent to stand trial. The examining psychologists opined that Snyder suffers from a severe intellectual disability arising from microcephaly. They described Snyder as: "extremely impaired and in the lower end of the Mild Mental Retardation range"; "suffering from a Pervasive Developmental Disorder that is directly related to microcephaly"; and having short-term memory that is "significantly below average." On May 23, 2013, the district court found Snyder not competent to stand trial and ordered him committed to Larned State Hospital (Larned) for evaluation and treatment for a period not to exceed 90 days.

         Because it is relevant to this factual summary, we pause now to address Snyder's motion under K.S.A. 60-409 for judicial notice of the nature of microcephaly. Snyder has recited medical facts about microcephaly and its attending disabilities. The State does not oppose the motion and does not contest the common definition of microcephaly as a medical condition in which a baby's head is smaller than normal, often present at birth and accompanied by lifelong intellectual disability. Further, the evidence in the record is clear that Snyder suffers from the condition of microcephaly and his intellectual disabilities all stem from this ...


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