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Name: People v. Easter
Case #: A148197
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 04/11/2019

Murder conviction reversed because trial court failed to reinstate competency proceedings despite evidence of defendant’s worsened symptoms of mental illness, which prohibited him from assisting in his defense. Easter was charged with the murder of his wife. Prior to trial, defense counsel expressed a doubt about Easter’s competency to stand trial. Criminal proceedings were suspended and a psychiatrist was appointed to examine Easter. The doctor found he was incompetent to stand trial. A psychologist appointed to give a second opinion concluded that Easter was competent to stand trial. A jury found him competent to stand trial and the criminal case resumed. Six months later (thirteen months after the evaluations) and days before trial, defense counsel on several occasions raised concerns regarding a deterioration in his client’s mental acuity and his new “word salad” responses to certain questions. The trial court declined to reinstate competency proceedings finding no change of circumstances or new evidence which cast doubt on the prior competency finding. Easter was convicted of first degree murder. He appealed. Held: Reversed. A defendant whose mental disorder renders him unable to understand the nature of the criminal proceedings or to assist counsel in the conduct of a defense in a rational manner, is incompetent to stand trial (Pen. Code, § 1367). Where a competency hearing has already been held and the defendant found competent to stand trial, the trial court need not suspend proceedings to hold another competency hearing unless it is presented with a substantial change of circumstances or new evidence which casts serious doubt on the validity of the competency finding. Here, trial counsel provided specifics about Easter’s deteriorating mental health, which included a new “word salad” symptom not previously manifested. This alone constituted a substantial change of circumstances which necessitated another competency proceeding. Because a retrospective competency proceeding would not be fair or produce a reliable result, the judgment of conviction was reversed.

The full opinion is available on the court’s website here: