State v. Bauer

245 N.W.2d 848, 310 Minn. 103, 1976 Minn. LEXIS 1811
CourtSupreme Court of Minnesota
DecidedAugust 20, 1976
Docket44075
StatusPublished
Cited by51 cases

This text of 245 N.W.2d 848 (State v. Bauer) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Bauer, 245 N.W.2d 848, 310 Minn. 103, 1976 Minn. LEXIS 1811 (Mich. 1976).

Opinion

Yetka, Justice.

Defendant appeals his conviction in the St. Louis County District Court of murder in the second degree. He was indicted in Hennepin County District Court for first-degree murder in the shooting death of a Minneapolis police officer on February 4, 1972, but this court, on defendant’s motion, ordered a change of venue to St. Louis County. On June 9, 1972, defendant was sentenced and committed to the custody of the commissioner of corrections for a maximum term of 40 years with a recommendation that he not be paroled. We reverse.

As to the evidence of the commission of the crime, there is little dispute. On January 27, 1972, a letter synopsizing the defendant’s history of mental illness and stating that he was dangerous and in urgent need of treatment was sent to the United States Secret Service by Dr. Daniel Ferguson, M. D., of the Mental Health Clinic of the Veteran’s Administration Hospital, where defendant had been undergoing psychiatric treatment. As a result, a petition for judicial commitment was granted and an order directing the Hennepin County sheriff to apprehend and confine the defendant for psychiatric examination was issued by the Hennepin County probate court.

On February 4, 1972, two deputy sheriffs in plain clothes and *105 two Minneapolis uniformed police officers went to the defendant’s apartment in northeast Minneapolis to serve the commitment papers and to apprehend the defendant pursuant to the probate court order. After being denied admittance to the defendant’s second story apartment, Officer Joseph Pudlick kicked in the door and entered along with one of the deputy sheriffs and the other police officer. The defendant fired three shots at them from inside the apartment, and while they retreated down the stairs, fired two additional shots, one of which killed Officer Pudlick. After tear gas capsules were shot into the apartment, the defendant surrendered.

At the defendant’s arraignment in Hennepin County District Court, the court ordered a pre-plea psychiatric examination to determine the defendant’s competency to stand trial. 1 He was initially screened by the court psychologist who, in a report to the court, concluded:

“In summary, Mr. Bauer’s paranoid distrust is too great for him to share facts with anyone. He is adamant in his belief that others are not to be trusted, and that others will only pretend to help or defend him. This delusion is sufficiently generalized to include all of the legal profession, psychology, and psychiatry. He refuses to take medication that could alter his condition and make him more accessible. The question seems to be one of whether he is unwilling or unable to participate with counsel in *106 the preparation and implementation of his defense. He will be evaluated in the near future by Dr. Carl P. Malmquist, consulting psychiatrist. Dr. Malmquist will address himself to the competency question.”

During the course of his interview with Dr. Malmquist, the defendant was, as he had been with the court psychologist, generally uncooperative, refusing to discuss anything relating to the shooting or leading up to it. While concluding, on the basis of the information then available, that the defendant was merely unwilling to discuss the shooting, Dr. Malmquist in his report added the caveat that a more extensive psychological history and examination might reveal a delusional basis for defendant’s uncooperative attitude which would render him incapable of participating in his defense. The defendant’s past medical history was not available to Dr. Malmquist, apparently for the reason that the defendant refused to waive his medical privilege.

Following a second interview with the defendant, Dr. Malm-quist concluded at a hearing on March 15, 1972, before Judge Crane Winton that the defendant was not incapable of cooperating in his defense, but only unwilling to do so and accordingly was competent to stand trial. On that basis Judge Winton ruled the defendant competent.

On April 20, 1972, more than a month after that competency hearing, Dr. Malmquist made a second report based on a third interview with the defendant, conducted at the defendant’s request. The defendant was markedly more communicative during that interview about the details leading up to the shooting, although he still refused to discuss the actual events of the shooting. Dr. Malmquist .did not expressly revise his prior opinion of competency^ but concluded with the following:.

“It is my impression that at this point Mr. Bauer is still insistent on wanting a trial to present his version of the events. There is the danger of this individual, having episodes where he may not be able to function adequately in court. That is a very diffi *107 cult thing to predict given the unknowns that can occur during the course of a trial. He again, states that it is a matter of his not wishing to discuss further details with a lawyer. At this time I could only offer the opinion that he may regress during a trial so that at those times procedures would be interfered with. He does not view his state now as one of needing hospitalization, nor does he want it at this time. He is opposed now, as he was the first time I saw him, to medical, or legal, attempts to certify him as incompetent so that the story he wishes to present would not come forth. He is on no medications at this time to my knowledge. It will be a matter of assessing what degree of competency he must have, to not only cooperate with an attorney (which he does not wish to do), but to also conduct his own defense.” (Italics supplied.)

During the pretrial hearings, the defendant repeatedly asserted his right to proceed pro se. As a result, Judge 'Winton appointed the public defender, apparently not to represent the defendant, but to act in the capacity of standby counsel, 2 offering assistance to the defendant only at his request. ■

The defendant filed an affidavit of prejudice against Judge Winton and by order by this court he was removed from the case.

The trial began May 30, 1972, before Hennepin County District Court Judge Bruce Stone. The defendant renewed his demand to proceed pro se, reiterating his belief that the public defender had been appointed to conceal his story of the shooting. Judge Stone, apparently because of the defendant’s refusal to *108 participate in the trial, allowed the public defender to conduct certain stages of the. defense. But the defendant was also permitted to participate directly in his defense whenever he would assert his right to proceed pro se. A result, in part, of this dual representation was that no defense was offered on behalf of the defendant.

At the close of the prosecution’s case, the public defender moved the court to suspend the trial for further inquiry into the defendant’s competency to stand trial. The motion was denied.

The jury was instructed on murder in the first, second, and third degrees. The public defender’s motion that there be an instruction on not guilty by reason of insanity was denied.

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Bluebook (online)
245 N.W.2d 848, 310 Minn. 103, 1976 Minn. LEXIS 1811, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-bauer-minn-1976.