Competence to stand trial should require rational understanding.

Rationality is explicit in the United States Supreme Court's Dusky standard but not in most U.S. CST standards. It is hard to imagine that the legal purposes of competency to stand trial (CST) determinations are served if a defendant's understanding of the proceedings is irrational (e.g., delusional or psychotically confused) or if the defendant cannot consult rationally with counsel. Most insanity tests include a rationality criterion. In United States v. Timmins, the Ninth Circuit emphasized the importance of rationality in CST in an opinion that also illustrated that the district court applied the federal standard, which does not mention rationality, without considering rationality. With its recent decision in Panetti v. Quarterman, the United States Supreme Court now requires rational understanding for competence to be executed. If there had been any doubt that unqualified understanding is not invariably taken to mean rational understanding by trial and appellate courts, the legal history of Panetti now dispels this misapprehension. The time is ripe for recognition of a uniform standard of CST that requires rationality.