This is a juvenile proceeding against Michael A., then 13 or 14. At the request of the defense, the court granted a continuance so that a psychologist could determine if Michael was competent to understand the proceedings and cooperate with counsel.

The psychologist concluded that there was a gross inability to assist counsel. The bases of the conclusion included the fact that Michael had been diagnosed with FAS.

The trial court, without holding a hearing, ruled that Michael was competent to stand trial. The appellate court reversed, holding that the trial court was required to hold a hearing on Michael's competency to stand trial.