Competency to Stand Trial, Minimal On‑Record Findings, and Reliance on Psychiatric Reports: Commentary on Chun‑Castro v. State (Del. 2025)

1. Introduction

The Delaware Supreme Court’s decision in Chun‑Castro v. State addresses a recurring but often difficult problem in criminal procedure: when and how a trial court must determine that a defendant is competent to stand trial, and what due process requires in terms of factual findings and explanation on the record.

The case arises from serious sexual offenses committed against a minor. The defendant, Ismar H. Chun‑Castro, was indicted on multiple counts of first-degree rape, first-degree sexual abuse of a child by a person in a position of trust, authority, or supervision, and unlawful sexual contact. His counsel consistently expressed concern about his client’s ability to participate in his defense, despite the defendant’s apparent understanding of the charges and proceedings.

The opinion is significant in several respects:

• It reaffirms and sharpens Delaware’s already “quite low” threshold for competency to stand trial.
• It clarifies that a trial court may satisfy its duty to make findings and “state the reasons” for a competency ruling by explicitly relying on written psychiatric evaluations, even with only brief oral remarks on the record.
• It rejects the notion that rejecting favorable plea offers, or failing to grasp technical plea labels like an Alford plea, is itself strong evidence of incompetence.
• It underscores the centrality of the McGarry factors (as applied through State v. Shields) as the operative evaluative tool for competency determinations in Delaware.

Taken together, Chun‑Castro consolidates Delaware law on competency and sets practical expectations for trial judges and defense counsel when competency is questioned—especially in cases where psychiatric reports are the primary evidence.

2. Factual and Procedural Background

2.1 Charges and Indictment

On March 23, 2021, the State of Delaware initially indicted Ismar Chun‑Castro for criminal sexual intercourse with a minor. By a superseding indictment on December 8, 2023, the State charged him with:

• 2 counts of first-degree rape;
• 6 counts of first-degree sexual abuse of a child by a person in a position of trust, authority, or supervision; and
• 8 counts of first-degree unlawful sexual contact.

2.2 Early Competency Concerns

At a February 2022 teleconference, defense counsel first raised concerns about competency. Counsel’s description is instructive, and the Supreme Court later relies on it to frame the issue:

Counsel explained that:

• Chun‑Castro appeared to understand the nature of the proceedings and the charges.
• However, he seemed unable to “engage in his own defense,” in the sense of making rational choices about how to respond to the charges.
• His thinking did not fit the usual pattern of defendants who may have unrealistic expectations but still reason within the legal framework.

Counsel requested a psychological evaluation. The Superior Court granted the request, and the defendant was evaluated by a forensic psychologist.

2.3 First Evaluation – Incompetent Based on Refusal to Defend

On September 29, 2022, Dr. Constance Mesiarik evaluated the defendant at the Delaware Psychiatric Center and issued a written report:

• She found that he had a “generally adequate understanding” of the criminal process and his involvement.
• However, he repeatedly stated that he would not defend himself against the charges.
• Because of this refusal to participate in his defense, Dr. Mesiarik concluded that he was incompetent to stand trial.

After receiving this report, the Superior Court directed counsel to notify the court within 10 days if a competency hearing was requested; otherwise, the court would assume no hearing was needed. Defense counsel did not request a hearing. Instead, the parties agreed to attempt competency restoration.

2.4 Competency Restoration Program and Second Evaluation

By agreement of counsel and the State, the court ordered that Chun‑Castro be transferred to the Delaware Psychiatric Center to participate in a competency restoration program. After completion, a second evaluation was performed on April 5, 2023, by Dr. Jonathan P. Tan.

Dr. Tan’s report:

• Confirmed that Chun‑Castro continued to have a rational and factual understanding of the charges and court process.
• Observed that he had “actively participated in the competency restoration program.”
• Recorded that Chun‑Castro now expressed confidence in his lawyer and stated that he would “actively participate” in his defense.
• Applied the McGarry criteria (as used in State v. Shields) and concluded, “within a reasonable degree of psychological certainty,” that Chun‑Castro was competent to stand trial.

2.5 April 2023 Teleconference and Setting the Trial

The Superior Court then held an April 26, 2023 teleconference with counsel:

• The judge explicitly noted on the record that there had been an earlier report finding incompetence and a more recent report finding the defendant competent.
• Defense counsel still expressed doubts about competency but, notably, said he had no problem with his client entering a plea.
• The court reminded counsel that a defendant must be competent to accept a plea and suggested a third evaluation if counsel genuinely doubted Dr. Tan’s conclusions.
• Counsel was unsure about obtaining a third evaluation, citing funding limitations: the family had stopped paying for experts, the State was unlikely to sponsor another evaluation after a favorable report, and conflict-counsel funding was uncertain.
• The State asked for a trial date; defense counsel agreed a trial could be set, requesting that it not be scheduled too soon to allow more consultation with his client.
• The court set the trial and invited counsel to raise any further competency concerns if they arose.

Counsel never renewed the competency objection in a way that sought a hearing or a third evaluation.

2.6 Plea Discussions and Trial

On July 28, 2023, in another teleconference, defense counsel advised the court that:

• He had attempted to assist his client in considering plea offers.
• All efforts to persuade Chun‑Castro to accept a plea had failed.
• He was nonetheless ready for trial.

At trial, the State dropped six charges. A jury convicted the defendant on:

• 2 counts of first-degree rape,
• 6 counts of child abuse, and
• 2 counts of unlawful sexual contact.

He was sentenced to a total of 216 years at Level V incarceration (with credit for approximately 3.5 years of time served).

2.7 Appeal

On appeal to the Delaware Supreme Court, Chun‑Castro advanced two principal arguments:

1. The Superior Court violated his due process rights by ruling on competency without making adequate factual findings or explaining its reasoning on the record.
2. The record as a whole shows he was not actually competent to stand trial.

The Supreme Court (Griffiths, J.) rejected both arguments and affirmed.

3. Summary of the Opinion

3.1 Standard of Review

The Court distinguishes between:

• Legal standard for competency – reviewed de novo (fresh review).
• Factual findings on competency – reviewed deferentially; if supported by evidence, they are entitled to deference.

This aligns with prior Delaware cases, such as Cooke v. State.

3.2 Issue One: Due Process and Adequacy of the Competency Ruling

The defendant argued that the trial court:

• Failed to hold a separate, formal competency hearing after the second evaluation.
• Failed to “adequately create a record and explain its legal rationale” for finding him competent.

The Supreme Court:

• Reaffirmed that convicting a legally incompetent person violates due process (Harris v. State; Pate v. Robinson).
• Cited 11 Del. C. § 404(a), which broadly outlines the competency standard and authorizes confinement and treatment until the accused is capable of standing trial.
• Reaffirmed, via Holden v. State and Husband M. v. Wife D., that judges must make factual determinations and provide at least a brief legal rationale for decisions.

However, the Court held that the Superior Court adequately grounded its ruling in the record:

• The Superior Court explicitly referenced the initial report finding incompetence and the later report finding competency.
• It was clear from the record that the court relied on these reports—and especially Dr. Tan’s detailed McGarry-based assessment—to conclude that competency had been restored.
• This reliance, briefly acknowledged on the record, satisfied the requirement to “state the reasons” for the decision.

Thus, there was no due process violation.

3.3 Issue Two: Was the Defendant Competent to Stand Trial?

On the merits, the Court:

• Reiterated that the legal standard for competency is “quite low” and “neither very demanding nor exacting.”
• Restated the core test:
  • Sufficient present ability to consult with counsel with a reasonable degree of rational understanding.
  • A rational as well as factual understanding of the proceedings and charges.
  • Ability to assist in preparing a defense.

Applying that standard, the Court emphasized:

• Dr. Tan’s detailed application of the McGarry factors, which strongly supported competence post-restoration.
• The defendant’s understanding of:
  • The charges (including their felony nature and seriousness);
  • Possible penalties (over ten years’ incarceration);
  • The roles of the judge, jury, prosecutors, witnesses, and defense counsel;
  • The basic structure of plea bargaining.
• His articulated willingness and ability to work with counsel after the restoration program.

The defense had argued:

• That the defendant’s rejection of plea offers, despite having confessed and facing an effective life sentence, showed an inability to weigh options.
• That his failure to understand an “Alford plea” (no-contest plea) indicated incompetence.

The Supreme Court rejected both contentions:

• It found the defendant knowingly and voluntarily declined plea offers after understanding their advantages; his choice was influenced by religious beliefs, not incompetence.
• It noted that the competency standard does not require a defendant to understand all specific legal terminologies or professional defense techniques; this would improperly raise the threshold.
• It emphasized that the defendant actually declined to discuss his defense strategy with Dr. Tan because he preferred to discuss it only with his lawyer, which shows a rational grasp of confidentiality and legal strategy, not a deficit.

In light of the totality of the record, the Court held that the Superior Court’s determination of competency was supported by sufficient evidence and must be upheld.

4. Detailed Analysis

4.1 Legal Framework: Competency and Due Process in Delaware

4.1.1 Constitutional Baseline

Under the Due Process Clause (as articulated in Pate v. Robinson and adopted by Delaware in cases like Harris v. State), a defendant may not be tried or convicted while legally incompetent. Competency is a prerequisite to a fair trial.

4.1.2 Statutory Framework – 11 Del. C. § 404(a)

Delaware’s key statutory provision, 11 Del. C. § 404(a), provides that:

Whenever the court is satisfied, after hearing, that an accused person, because of mental illness or serious mental disorder, is unable to understand the nature of the proceedings against the accused, or to give evidence in the accused’s own defense or to instruct counsel on the accused’s behalf, the court may order confinement and treatment until the accused is capable of standing trial.

Important points:

• The focus is on capacity to understand and to communicate with counsel, not on sanity at the time of the offense.
• The statute contemplates a “hearing,” but Delaware case law does not require a full-blown evidentiary hearing in every instance; teleconferences and reliance on written forensic reports can, in context, satisfy the requirement, particularly where the parties do not insist on a formal hearing.
• The remedy for lack of competence is treatment and confinement until competency can be restored—precisely what occurred here.

4.1.3 The Delaware Competency Standard

Delaware follows the general Dusky standard (from Dusky v. United States) as applied and elaborated in state cases like Gibson v. State, Cooke v. State, and State v. Shields:

• The defendant must:
  • Have sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding;
  • Have a rational as well as factual understanding of the proceedings;
  • Be capable of assisting in the preparation of his defense.

The Court underscores that “the competency threshold is quite low” and is not measured against a reasonable person standard but the “average criminal defendant.” This is critical: the law is deliberately tolerant of poor judgment, strong emotions, and non‑lawyer confusion about procedures, as long as basic understanding and communicative ability are present.

4.2 Precedents Cited and Their Influence

4.2.1 Harris v. State, 410 A.2d 500 (Del. 1979)

Harris is cited for the foundational due process principle: convicting a legally incompetent defendant violates due process. The Court in Chun‑Castro invokes Harris to reaffirm that competency is not merely statutory but constitutionally required.

4.2.2 Cooke v. State, 338 A.3d 418 (Del. 2025)

Cooke supplies two important elements:

• The standard of review: legal questions about competency are reviewed de novo, but factual findings are given deference if supported by the record.
• The reaffirmation that the competency threshold is “quite low” and not “very demanding nor exacting.”

Chun‑Castro relies on Cooke to justify substantial deference to the trial court’s implicit factual determination that the defendant was competent, particularly in light of the forensic evaluations.

4.2.3 Gibson v. State, 981 A.2d 554 (Del. 2009)

Gibson restates the Dusky standard and emphasizes deference to trial court findings when supported by the record. It reinforces that the appellate court does not re‑weigh evidence de novo but asks whether the evidence supports the trial judge’s conclusion.

4.2.4 State v. Shields, 593 A.2d 986 (Del. Super. 1990)

Shields is pivotal in Delaware’s practical approach to competency because it adopted the McGarry criteria as a structured tool for evaluating competency.

In Chun‑Castro:

• Dr. Tan explicitly applied the “McGarry questions” as used in Shields.
• The Supreme Court highlighted this, signaling that forensic evaluations grounded in McGarry carry particular weight in competency determinations.

Thus, Shields functions as the methodological backbone for forensic assessment in Delaware.

4.2.5 Holden v. State, 23 A.3d 843 (Del. 2011) & Husband M. v. Wife D., 399 A.2d 847 (Del. 1979)

These cases are cited for the principle that:

• Judges must make factual determinations and provide a rationale for their decisions.
• Even brief explanations can suffice; what matters is that some reasoned basis appears on the record.

Chun‑Castro leans on these cases to reject the argument that the trial court’s explanation was too sparse. The Court finds that expressly referencing the two reports and moving to trial on that basis was an adequate statement of reasons, particularly when the reports themselves are detailed.

4.2.6 Tucker v. State, 105 A.3d 990, 2014 WL 7009954 (Del. Nov. 21, 2014) (TABLE)

Tucker is cited to reaffirm the core components of the competency standard, emphasizing the ability to assist in preparing a defense. It supports the proposition that factual understanding and communicative ability are central.

4.2.7 State v. Williamson, 2013 WL 268981 (Del. Super. Jan. 23, 2013)

The defense invoked Williamson for the proposition that competency determinations must look to the totality of the circumstances, not solely to psychiatric reports.

The Supreme Court in Chun‑Castro does not reject this principle but effectively holds:

• That the trial court did consider the totality—including plea negotiations and the defendant’s demeanor as relayed by counsel.
• That the psychiatric reports, especially Dr. Tan’s, were compelling and not credibly contradicted by other evidence.

In effect, Chun‑Castro reconciles Williamson by saying: yes, totality matters, but in this totality the psychiatric evidence predominates and supports competence.

4.3 The Court’s Legal Reasoning in Chun‑Castro

4.3.1 Due Process and “Minimalist” On‑Record Findings

The first major holding is that the trial judge’s handling of the competency question satisfied due process and Delaware’s requirement to state reasons.

Key points in the Court’s reasoning:

• The record makes clear that:
  • The court ordered an initial evaluation, found incompetence, and then ordered a restoration program.
  • After restoration, the court obtained a second evaluation explicitly finding restored competency, with detailed McGarry-based analysis.
• At the April 2023 teleconference, the judge explicitly referenced the prior “not competent” report and the “more recent one” finding the defendant “now competent.”
• The decision to set the case for trial, after referencing the reports, is an implicit but clear finding of competency grounded in those evaluations.
• The judge also invited further issues to be raised and even suggested a third evaluation if counsel remained concerned, indicating continuing sensitivity to competency problems.

From this, the Supreme Court concludes:

We hold that the Superior Court satisfied its responsibility to briefly “state the reasons for [its] action” when it determined Chun‑Castro’s competency based on the reports.

In other words:

• A formal, written finding is not required.
• A brief on‑record acknowledgment that the court is relying on specified expert reports can suffice as an explanation.
• So long as the record shows what the judge considered and why, due process is satisfied.

This is an important practical precedent: it validates an efficient, report-centered approach where the forensic record is strong and uncontroverted, and the parties do not actively contest it with contrary evidence.

4.3.2 Affirming Competency Under the “Low Threshold” Standard

The second major holding is that the Superior Court’s finding of competency was supported by the record.

The Supreme Court emphasizes several elements drawn from Dr. Tan’s McGarry-based evaluation:

• Understanding the charges – The defendant knew he faced 17 offenses, recognized they were felonies, and appreciated their seriousness.
• Understanding possible penalties – He knew a conviction would lead to imprisonment exceeding ten years.
• Understanding the roles of courtroom actors – He correctly identified the roles of judge, jury, prosecutor, and defense counsel, and knew who would decide guilt and who would impose sentence.
• Understanding of witnesses and cross-examination – He understood that:
  • Witnesses would testify for or against him,
  • His lawyer would cross-examine them, and
  • He should alert his lawyer if a witness lied.
• Understanding of pleas and plea bargaining – He grasped:
  • The meaning of “guilty” and “not guilty” pleas;
  • The basic idea that plea bargaining could reduce his time in custody;
  • That his lawyer might negotiate “less time” via a plea deal.
• Ability to communicate and assist counsel – Post-restoration, he:
  • Expressed confidence in his lawyer,
  • Stated he would “tell anything” he knew to his lawyer, and
  • Indicated he understood his lawyer worked in his best interests.
• Defense strategy and confidentiality – He declined to discuss defense strategy with Dr. Tan because he wanted to discuss it only with his lawyer—behavior the Court characterizes as rational, not disordered.
• Courtroom behavior and managing stress – He understood he had to behave calmly in court, that disruption would be punished, and that he should tell his lawyer if he felt overwhelmed.
• Absence of self-defeating motivation – Although he spoke about surrendering to God’s will and accepting any outcome, Dr. Tan saw no evidence of “self-defeating motivation” in a psychiatric sense.

Critically, the Supreme Court uses these findings to demonstrate that the defendant met the low competency threshold—even if his decisions (e.g., rejecting plea offers, relying on divine providence) might be unwise from a purely strategic perspective.

4.3.3 Rejection of Plea Offers and Religious Beliefs

A central plank of the defense’s appellate argument was that:

• The defendant had confessed to the offenses.
• He repeatedly rejected plea offers despite facing a de facto life sentence.
• He attributed his fate to God’s will and was willing to accept a long sentence if that was God’s plan.
• Therefore, he was allegedly incapable of rationally weighing his options.

The Supreme Court rejects this inference:

• The record showed the defendant understood:
  • The nature and advantages of a plea deal;
  • The sentence exposure at trial;
  • The potential for a reduced sentence via a plea.
• His decision not to plead was thus a value-laden choice, driven by moral and religious beliefs, not by an inability to comprehend consequences or communicate with counsel.
• The court stresses that competency does not require that a defendant:
  • Make “wise” choices,
  • Follow counsel’s advice, or
  • Place secular legal advantage over personal moral or spiritual commitments.

In doctrinal terms, the Court distinguishes between:

• Rational understanding and communicative capacity (which are required), and
• Reasonable decision-making in a normative sense (which is not required).

This distinction is central to the entire competency doctrine and is reinforced here.

4.3.4 Failure to Understand “Alford Plea” Does Not Equal Incompetence

The defense also argued that because the defendant did not understand an “Alford plea” (a form of no-contest plea), he was unable to assist in his own defense.

The Court responds in two ways:

1. It clarifies the record:
   • Dr. Tan did not say the defendant was unable to understand defense strategies.
   • Rather, the defendant declined to share his strategy with Dr. Tan, choosing to keep that discussion between himself and counsel—a rational response.
2. It emphasizes the low threshold for competency:
   • A defendant need not understand every technical plea type or every nuanced legal strategy.
   • Requiring such understanding would impermissibly heighten the competency standard beyond what Delaware law permits.

Thus, confusion about an Alford plea (a concept many non-lawyers find abstract) does not seriously undercut a competency finding where the defendant otherwise comprehends the core options of pleading guilty or not guilty and of engaging in plea bargaining.

4.3.5 Totality of Circumstances and Deference to the Trial Court

Finally, the Court addresses the “totality of circumstances” argument built on Williamson:

• It acknowledges that a competency determination must consider all relevant evidence, not just psychiatric reports.
• It notes that the trial judge was aware of, and took into account, the plea rejections and counsel’s early concerns.
• However, it finds that the later, detailed McGarry-based competency evaluation, combined with counsel’s eventual representation that he was “ready for trial,” provided a sufficient evidentiary basis for a competency finding.

The Court thus defers to the trial judge’s implicit factual finding, as required by Gibson and Cooke, because:

• The finding is supported by substantial evidence (the Tan report and other aspects of the record).
• No strong countervailing evidence was presented (e.g., no competing expert report or diagnosis).

5. Complex Concepts Simplified

5.1 “Competency to Stand Trial” vs. “Insanity”

It is crucial to distinguish:

• Competency to stand trial – Focuses on the defendant’s current ability to:
  • Understand the charges and proceedings, and
  • Work with counsel to mount a defense.
  It is about present capacity.
• Insanity (or mental responsibility) at the time of the offense – Concerns whether the defendant was legally responsible at the moment of the crime, often involving whether he could distinguish right from wrong or conform his conduct to law.

Chun‑Castro deals only with competency to stand trial; the defendant’s guilt and responsibility for the past acts were adjudicated by the jury and are not directly at issue in this opinion.

5.2 The McGarry Factors

The McGarry factors are a set of structured questions originally developed by Dr. Thomas McGarry to assess competence. Delaware, through State v. Shields, has adopted these as a practical tool. Although formulations vary, they typically examine:

• Understanding of the charges;
• Understanding of possible penalties and verdicts;
• Understanding of roles of judge, jury, prosecutor, and defense counsel;
• Understanding of courtroom procedures and pleas;
• Ability to communicate with counsel and disclose relevant information;
• Ability to evaluate evidence and potential defenses;
• Capacity to behave appropriately in court and tolerate stress;
• Presence or absence of self-defeating or bizarre motivations.

In Chun‑Castro, Dr. Tan systematically went through these domains, and his positive findings across them strongly supported the conclusion that the defendant was competent.

5.3 Competency Restoration Programs

A competency restoration program is a structured treatment and education regime designed to help an incompetent defendant attain competence. It may involve:

• Medication and therapy for underlying mental illness;
• Education about legal rights, courtroom roles, and procedures;
• Skills training for communicating with counsel and managing courtroom stress.

Here, the restoration program seems to have:

• Addressed the defendant’s prior refusal to engage with his defense;
• Helped him appreciate the necessity of working with counsel;
• Led to his expressed willingness to participate actively in his defense.

5.4 Alford Plea (No-Contest Plea)

An Alford plea (from North Carolina v. Alford) is a type of plea in which:

• The defendant maintains factual innocence or does not admit to the conduct;
• But consents to conviction because he recognizes that the State’s evidence is strong and that pleading may result in a more favorable outcome than trial.

In practice, it functions similarly to a guilty plea for sentencing purposes, but with a different allocution. Many jurisdictions treat it as a form of “no contest” plea.

Chun‑Castro clarifies that:

• Understanding the distinction between an Alford plea and a standard guilty plea is not required to be competent.
• What matters is that the defendant understands basic options—plead guilty or go to trial—and the general concept of plea bargaining.

5.5 Deference to Trial Courts on Competency

Appellate courts in Delaware show deference to trial courts on competency findings because:

• Trial judges see the defendant in person, observe demeanor, and interact with counsel directly.
• They are better positioned to evaluate subtleties that a paper record may omit.

Thus, as in Chun‑Castro, if the record contains reasonable evidence supporting the trial judge’s conclusion—and no compelling contrary evidence—the Supreme Court will generally affirm.

6. Impact and Implications

6.1 Reinforcing a Low Threshold for Competency

The decision reemphasizes that Delaware’s standard for competency is:

• “Quite low;”
• Not “very demanding nor exacting;”
• Not tied to the “reasonable person,” but to the “average criminal defendant.”

Practically, this means:

• Defendants may hold strong religious, moral, or idiosyncratic beliefs.
• They may reject seemingly rational legal advice.
• They may lack detailed understanding of technical legal doctrines.
• None of that necessarily implies incompetence, so long as they understand the basics and can communicate with counsel.

6.2 Minimal On‑Record Explanation Can Suffice

The case clarifies that:

• A trial court need not deliver a lengthy, formalized competency ruling.
• Explicit reliance on detailed forensic evaluations, acknowledged on the record, can be a sufficient explanation.
• What is key is that the record reveals:
  • What evidence the court relied on;
  • That the court understood prior and current competency findings; and
  • That it made a deliberate, reasoned choice to proceed to trial.

This provides guidance and some comfort to busy trial courts faced with routine but important competency questions: thorough psychiatric evaluations plus a clear, if brief, on-record acknowledgment can withstand appellate scrutiny.

6.3 Role of Defense Counsel and the Importance of Making a Record

Chun‑Castro highlights:

• The strategic and ethical importance of defense counsel’s decisions about:
  • Requesting competency hearings,
  • Challenging forensic opinions, and
  • Seeking additional evaluations.
• Here, counsel did not request a formal competency hearing after the first evaluation (beyond the colloquies), and—after the positive Tan report—did not successfully seek a third evaluation, in part due to funding issues.
• Ultimately, counsel reported being “ready for trial,” which the Supreme Court views as consistent with, rather than contrary to, the finding of competence.

For future cases:

• If counsel seriously disputes competency despite favorable forensic reports, it is critical to:
  • Formally request a competency hearing;
  • Seek funding for independent experts and document any denials;
  • Build a detailed record of observations that contradict the expert conclusions.

Absent such a record, appellate courts are likely to defer to trial courts and the State’s experts, particularly when McGarry-based evaluations are unchallenged.

6.4 Plea Rejections and Religious or Moral Reasoning

The decision is significant in confirming that:

• Rejecting a plea, even an extremely favorable one, is not itself evidence of incompetence, even where guilt is overwhelming.
• Defendants may rationally choose to:
  • Contest charges as a matter of conscience,
  • Submit their fate to what they perceive as divine will, or
  • Refuse to “lie” by pleading guilty even when such a plea would be strategically advantageous.

This is consistent with broader U.S. Supreme Court principles respecting defendant autonomy (e.g., the recognition in McCoy v. Louisiana that the decision to maintain innocence at trial is ultimately the defendant’s). While McCoy is not cited here, the spirit is congruent: rational but morally or religiously motivated decisions must still be honored.

6.5 Strengthening the Role of McGarry-Based Evaluations

By highlighting Dr. Tan’s use of McGarry questions and underscoring how they map closely onto the legal competency standard, Chun‑Castro reinforces:

• The importance of structured forensic tools in competency evaluations;
• The evidentiary weight given to such reports when they are thorough and uncontradicted;
• The likelihood that appellate courts will rely heavily on these tools in reviewing competency determinations.

7. Conclusion

Chun‑Castro v. State is a consequential decision for Delaware criminal practice and mental-health law. It affirms that:

• Convicting an incompetent defendant violates due process, but the legal threshold for competency remains low and pragmatic.
• Trial courts may rely heavily—and explicitly—on detailed psychiatric evaluations to determine competency, and a brief on‑record explanation referencing those evaluations can satisfy the duty to state reasons under cases like Holden and Husband M.
• The “totality of the circumstances” test does not require courts to disregard or second-guess credible forensic evidence simply because the defendant makes morally or religiously driven decisions that seem unwise from a purely legal standpoint.
• Confusion over technical legal terms, such as “Alford plea,” does not undermine competency where the defendant otherwise understands core plea options, trial processes, and the roles of courtroom actors.

In practice, Chun‑Castro encourages trial courts to:

• Order forensic evaluations promptly when competency is in question;
• Use structured tools like the McGarry factors;
• Place their reliance on such reports clearly on the record; and
• Remain receptive to further concerns, but not to treat every risky or unconventional defendant decision as proof of incompetence.

For defense counsel, the decision underscores the importance of:

• Creating a robust record if they genuinely dispute competency findings;
• Understanding the low legal threshold and tailoring their arguments accordingly; and
• Recognizing that courts will distinguish between irrational decision-making due to mental disorder and rational, value-laden choices that merely depart from counsel’s advice.

Overall, Chun‑Castro consolidates and clarifies Delaware’s approach to competency to stand trial, balancing due process protections for mentally disordered defendants with the need for efficient adjudication and respect for defendant autonomy.