The Supreme Court concluded that CRS § 16-8.5-102(2)(b) includes threshold requirements. Further, the Court concluded that, while trial courts must guard against second-guessing a competency motion that’s in writing and contains specific facts that form the basis of counsel’s “good faith doubt” about a defendant’s competency (i.e., a motion that satisfies the threshold requirements of § 16-8.5-102(2)(b)), they retain sufficient discretion to reject a competency motion that rests on counsel’s inadequate proffer.

Here, the Court discerned no abuse of discretion in the district court’s rejection of defense counsel’s competency motion as inadequate. Therefore, it reversed the Court of Appeals’ judgment and remanded the case to that court with instructions to reinstate Lindsey’s judgment of conviction.

The Supreme Court concluded that evidence that a mental disease or defect prevented a defendant from forming the culpable mental state required by a charged offense is evidence relevant to the issue of insanity. Further, the Court concluded that a defendant, even one charged with specific intent crimes, cannot introduce evidence relevant to the insanity issue without first entering a plea of not guilty by reason of insanity (NGRI).

Here, because the district court allowed Rosas to introduce evidence relevant to the insanity issue without requiring him to enter an NGRI plea, the Court made the rule to show cause absolute. On remand, the district court must afford Rosas the opportunity to plead NGRI. If he doesn’t, he may not introduce the challenged evidence. If he does, the district court should order a sanity examination pursuant to CRS § 16-8-106.