Retrospective Postconviction Competency to Stand Trial Assessments.

In Commonwealth v. Chatman, 46 N.E.3d 1010 (Mass. 2016), the Supreme Judicial Court of Massachusetts affirmed the trial court’s denial of his motion for a new trial, which was based on his assertion that he was incompetent at his 2002 trial. The Chatman test was constructed in a 2013 appeal in this same case as a framework for retrospective evaluation of a defendant’s competency to stand trial, after the verdict, when the defendant’s competency was not raised at trial. The test did not change the substantive inquiry into the defendant’s “functional abilities” at the time of trial. However, under the Chatman test, the burden is shifted to the defendant to prove, by a preponderance of the evidence, that the Commonwealth would not have prevailed if the defendant’s trial competency had been raised at trial.