State v. Langston
| Decision Date | 09 April 2018 |
| Docket Number | A17-1136 |
| Parties | State of Minnesota, Respondent, v. Hiram Abdul Langston, Appellant. |
| Court | Minnesota Court of Appeals |
This opinion will be unpublished and may not be cited except as provided by Minn. Stat. § 480A.08, subd. 3 (2016).
Affirmed
Koochiching County District Court
Lori Swanson, Attorney General, St. Paul, Minnesota; and
Jeffrey Naglosky, Koochiching County Attorney, International Falls, Minnesota (for respondent)
Cathryn Middlebrook, Chief Appellate Public Defender, Amy Lawler, Assistant Public Defender, St. Paul, Minnesota (for appellant)
Considered and decided by Reyes, Presiding Judge; Jesson, Judge; and Randall, Judge.*
UNPUBLISHED OPINION
After being placed on probation, appellant Hiram Abdul Langston appeared before the district court for a probation-revocation hearing. Langston displayed disruptive conduct at the hearing, such as interrupting the court on multiple occasions, providing vague and evasive answers to questions, and submitting a large amount of paperwork with quasi-legal language. Concerned about his mental health, the district court ordered a competency evaluation which Langston refused to cooperate with over the course of several hearings. Throughout this process, the court asked Langston at least three different times if he wanted a lawyer to represent him. Langston refused each time.
Despite Langston's refusal to cooperate, an evaluator eventually submitted a report indicating that Langston's behavior was due to his personal beliefs that the government is illegitimate—including the court system. The report noted that while Langston's behavior may be unusual, it was not the product of mental illness. The district court scheduled a new hearing where it resumed Langston's probation-revocation process. After hearing the evidence, the court revoked Langston's probation. Langston appeals, arguing that he was not competent to proceed, that the district court did not adequately advise him of his rights, that he did not adequately waive his right to an attorney, and that the district court abused its discretion when it revoked his probation. We disagree and affirm the district court.
Appellant Hiram Abdul Langston was on probation, having pleaded guilty to first-degree assault in 2014 and given downward dispositional and durational departures by thedistrict court. Three months into his probationary sentence, Langston failed to complete a required nonviolence group program. He also submitted a urine test that came back positive for alcohol use, in violation of his probation. At a probation-violation hearing, Langston admitted that he failed to complete the nonviolence program and was sentenced to ten days in jail. The court reinstated the same probationary conditions, provided that Langston attend and finish the group program. Langston was represented by a public defender throughout these proceedings.
After the first probation violation, Langston again was accused of violating multiple terms of his probation—including failing to attend the nonviolence program. At a probation hearing on January 9, 2017, Langston appeared before the same judge who oversaw his initial plea, sentencing, and previous probation violation hearing. The judge began the hearing by giving Langston the usual advisories for a first appearance probation hearing, including the right to remain silent, the right to have a lawyer represent him throughout the probation process, the right to a hearing to contest the charges that he violated his probation, the right to confront witnesses and cross-examine those witnesses, the right to—or not to—testify, the right to see the government records against him, and if his probation was revoked, the right to appeal with the help of a lawyer.
Before this probation hearing, Langston had been represented by a public defender. But now, Langston was alone; and not just alone, but different—his demeanor changed. From the start of the hearing, Langston was disruptive—interrupting the judge's introduction of the case by referring to himself not as Hiram Abdul Langston, but as appearing on behalf of his "debtor," Hiram Abdul Langston. He handed the court a stackof papers that had the veneer of being legal documents with technical jargon, but were mostly incomprehensible. The rest of the hearing was filled with Langston repeatedly interrupting the court; digressing into long speeches attacking the court's legitimacy which were peppered with unintelligible legal jargon; and referring to himself as the secured party known as Hiram Langston. The district court tried to make sense of Langston's behavior, but the attempts to untangle Langston's identity went nowhere and the court ultimately decided to take Langston into custody and order a competency evaluation from a local evaluator.
Over the next three months, the court struggled to get Langston to cooperate with the competency evaluation. In fact, the court scheduled three separate status hearings1 between January 13 and March 21 and attempted to have Langston meet with a local evaluator, a county evaluator, and an evaluator from a state-operated agency, including allowing Langston to meet via video conference. Langston refused to cooperate each time. And at one of these status hearings, Langston interrupted the district court judge, a witness, and the prosecutor many times to declare that fraud was being committed upon the court and to use his time to speak at some length about obscure areas of contract law. Even afterbeing admonished by the judge to remain quiet, the interruptions became so severe that the court was forced to end the proceeding early and had Langston taken back to jail.
A competency report was filed with the court on April 14, 2017 and acknowledged that Langston did not cooperate with the evaluation. Nonetheless, after reviewing a litany of Langston's medical and legal records, the evaluator determined that Langston was competent. The evaluator's report explained that Langston's behavior was the product of his personal belief that the government is illegitimate. His behavior was "not the result of a mental illness," the report concluded, "but instead the result of a culturally or subculturally held belief system."
With the competency report in hand, the parties reconvened on April 24, 2017. There, the court—referencing the report—found Langston competent to proceed and resumed the probation-revocation process that had been suspended since the court ordered the competency evaluation back in January. The court then heard testimony from Langston's probation officer. After considering the charges and evidence, the court revoked Langston's probation and executed his 36-month sentence. Langston appeals.
Langston makes four arguments in his appeal.2 First, Langston argues that he was not competent to proceed and the district court's finding of competence is not supported by the evidence. Second, Langston claims the district court did not properly advise him of his right to an attorney during the probation-revocation process. Third, Langston arguesthat he did not adequately waive his right to an attorney which requires this court to automatically reverse his probation revocation. And fourth, Langston claims the district court abused its discretion when it revoked his probation because the public policies in favor of keeping him on probation outweighed any need to confine him. We analyze each issue in turn.
A criminal defendant is not competent if he lacks the ability to "rationally consult with counsel" or cannot "understand the proceedings or participate in the defense due to mental illness or deficiency." Minn. R. Crim. P. 20.01, subd. 2; see also State v. Ganpat, 732 N.W.2d 232, 238 (Minn. 2007). A finding that the defendant is competent must be supported by the "greater weight of the evidence." Minn. R. Crim. P. 20.01, subd. 5(f). We independently review the record to determine if the district court gave proper weight to the evidence produced and if its findings are adequately supported by the record. Ganpat, 732 N.W.2d at 238.
We will begin our discussion of Langston's argument first by reviewing the history of the competency proceedings leading up to the April 14, 2017 competency report. We then discuss the report's conclusions and the district court's decision finding Langston competent. Finally, we address Langston's arguments rebutting the court's decision, specifically that the state failed to meet its burden of proof and that he was not given enough time to object to the report.
Langston's competency status conferences
We start our review with the January 9, 2017 probation hearing. This was the first time Langston demonstrated unusual behavior. At this hearing, Langston was verbally combative, interrupted the court multiple times, and insisted he was not Hiram Langston but a creditor to the secured party known as Hiram Langston. Because of this behavior, the court ordered a competency evaluation.
But determining Langston's competency would be no simple matter. The next three months would see three separate status hearings that were meant to check-in and evaluate whether Langston was competent. Three hearings were needed because Langston refused to cooperate with the evaluation each time. For instance, Langston refused to meet with the first, local competency evaluator and told the district court that someone had come to meet him at the jail, but this person "wished to speak to Mr. Langston and I am not Mr. Langston." He echoed this explanation about the second evaluator, explaining to the district court that this evaluator's paperwork showed that he was there to speak with Hiram Langston. "I am no Hiram Langston," he told the court.
Langston's competency report
Langston remained uncooperative for the court's third attempt to have an evaluator meet him, this...
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