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Name: Anderson v. Gipson
Case #: 16-15338
Court: US Court of Appeals
District 9 Cir
Opinion Date: 09/06/2018
Summary

Petitioner entitled to federal habeas relief where his behavior at trial raised a “bona fide doubt” as to his competence to stand trial but the state trial court failed to order a competency hearing sua sponte. Anderson was convicted of spousal battery and other offenses in California after he assaulted his girlfriend. Prior serious felonies were found true and he was sentenced to 54 years to life under the Three Strikes law. His convictions were affirmed in state court and he exhausted his state remedies. He filed a federal writ petition challenging the trial court’s failure to order a competency hearing after he exhibited serious signs of mental incompetency at trial. The district court denied the petition and he appealed. Held: Remanded to the district court with orders to grant the writ petition unless the state affords defendant a new trial. A person whose mental condition prevents him from understanding the nature of the proceedings against him, effectively consulting with counsel, and assisting in preparing his defense may not be subject to trial. Where a defendant’s behavior displays incompetence the trial court violates due process by not suspending proceedings and ordering a competency evaluation. Here, Anderson declined to participate in voir dire, resulting in an arguably unfavorable jury (all females including two jurors with personal connections to domestic violence). He attempted suicide the eve of trial, did not object to being shackled at trial, and engaged in intermittent withdrawal from the proceedings and profane outbursts. This behavior created a “bona fide doubt” as to Anderson’s mental competency and due process required the trial to stop until a competency hearing had been held. Under AEDPA’s standard for federal habeas relief, the California Court of Appeal’s decision denying Anderson relief on this claim involved an unreasonable application of clearly established federal law.

The full opinion is available on the court’s website here: http://cdn.ca9.uscourts.gov/datastore/opinions/2018/09/06/16-15338.pdf