Supreme Court of Iowa
State of Iowa v. Lukouxs Alan Brown
January 17, 2025
Summary
The court reaffirmed that competency determinations are reviewed de novo because they implicate the constitutional right not to be tried while incompetent. It held that Iowa Code chapter 812 does not permit either party to obtain an independent psychiatric evaluation during the dispositional phase after court-ordered restoration treatment. Applying de novo review, the court concluded that Brown was unlikely to regain competency within a reasonable time, vacated the court of appeals decision, reversed the district court order, and remanded for further proceedings.