Our review of the record indicates that, notwithstanding appellant's limited intellectual abilities, the trial court properly inferred from the evidence presented that appellant was competent to proceed. In our collective view, the evidence identifies narrow areas of difficulty, principally in communicating with counsel during interrogation of witnesses. These difficulties do not compel reversal of the juvenile court's finding that appellant had the ability to understand and participate in proceedings and to consult with counsel. Retired judge of the district court, serving as judge of the Minnesota Court of Appeals by appointment pursuant to Minn. Const. P. 20.01, subd.
Researchers confirm the characteristics of youth that bear on a person's competency.
But these factors, immaturity, developmental delays, and emotional disorders unique to age, are measured in the assessment of competency, without attempting to give weight to age alone as a measure of the condition. But in light of appellant's previous experience with the juvenile court process, his understanding about the work of an attorney, his recollection of the reading of the Miranda rights, and his decision not to speak to police without counsel, we believe that appellant has a less sweeping kind of disability than what appears to be indicated by Dr. Nelson's generalized opinion.