9 N.Y.3d 20 (2007)
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A defendant with dissociative identity disorder can be deemed competent to stand trial if the prosecution proves by a preponderance of the evidence that the defendant understands the proceedings and can assist in their own defense, even if alternate personalities exist.
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Summary
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Mendez killed her boyfriend and was convicted of manslaughter. She had a history of mental illness and claimed incompetency to stand trial due to dissociative identity disorder. Three psychiatrists examined her and testified that she was competent. The trial court agreed and found her fit to stand trial. The New York Court of Appeals affirmed, holding that the prosecution met its burden of proving competency by a preponderance of the evidence. The court declined to create a rule that anyone with dissociative disorder is automatically incompetent.
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Facts
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Mendez called 911, stating she thought she killed her boyfriend. Police found the boyfriend dead in bed with a stab wound. Mendez admitted to stabbing him after an argument, motivated by his perceived infidelity and bad attitude toward her son. She provided detailed statements to the police, but refused to sign them, claiming they contained mistakes and expressing concern about self-incrimination.
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Procedural History
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Mendez was indicted for murder. The County Court ordered a competency exam, finding her competent. After requesting a new attorney, a second competency hearing was ordered. Three psychiatrists examined Mendez and reported her competent. The trial court found her competent to stand trial. At the non-jury trial, Mendez raised the affirmative defense of extreme emotional disturbance. The court found her guilty of manslaughter in the first degree. The Appellate Division affirmed, and the Court of Appeals affirmed the Appellate Division.
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Issue(s)
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Whether a defendant with dissociative identity disorder is competent to stand trial when the prosecution proves by a preponderance of the evidence that the defendant understands the proceedings and can assist in their own defense.
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Holding
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Yes, because the prosecution established the defendant’s competency by a preponderance of the evidence, and there was no evidence that one personality would have to understand and defend charges arising out of a crime committed by another personality.
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Court’s Reasoning
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The Court of Appeals relied on CPL 730.10(1), which defines an incapacitated person as someone who