State of Iowa v. Lukouxs Alan Brown

Defendant Lukouxs Brown was granted an interlocutory appeal of the district court’s ruling finding he had been restored to competency and reinstating the criminal proceedings against him. The court of appeals, on de novo review of the record, reversed the district court’s ruling and remanded for entry of an order suspending the criminal proceedings indefinitely and continuing restoration treatment under Iowa Code section 812.6. The State seeks further review and requests the supreme court overrule State v. Lyman, 776 N.W.2d 865 (Iowa 2010), and apply a correction-of-errors, substantial-evidence review of the district court’s finding of competency.

Holding: The defendant appeals from a district court order finding him competent to stand trial on the charge of murder in the first degree. Decision of Court of Appeals Vacated; District Court Order Reversed and Case Remanded.