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Name: People v. Edwards (2023) 88 Cal.App.5th 1259
Case #: C094784
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 03/07/2023
Summary

Sanctions were appropriate against the California Department of State Hospitals (DSH) because lack of hospital beds did not establish good cause or substantial justification for the delays in admitting defendants found incompetent to stand trial (IST). DSH failed to admit three IST defendants in a timely manner, and the defendants filed petitions for writs of habeas corpus. After an order to show cause, the trial court issued sanctions of $1,000 for each day past the trial court’s deadline that the defendants were not admitted, totaling $91,000. DSH appealed. Held: Remanded. Code of Civil Procedure section 177.5 gives the trial court the power to impose sanctions, not to exceed $1,500, for any violation of a court order without good cause or substantial justification. The lack of beds is not good cause or substantial justification where the ongoing problem has not yet been fixed despite widespread violations over multiple years.

An order imposing sanctions under section 177.5 must “recite in detail the conduct or circumstances justifying the order.” DSH argued that the written orders imposing sanctions failed to specify justification of the order in sufficient detail. One order contained sufficient detail that DSH lacked good cause or substantial justification for its failure to admit the defendants by the court-ordered deadline because it cited to People v. Aguirre (2021) 64 Cal.App.5th 652. The trial court was permitted, on remand, to either make sufficient findings or vacate its awards in the remaining orders.

Section 177.5 sanctions permit sanctions of up to $1,500 for each separate violation of a court order. In disagreeing with the holding in In re Chunn (2022) 86 Cal.App.5th 639, the Court of Appeal presumed the Legislature intended to limit sanctions under section 177.5 to $1,500 for each separate violation of a court order that was found by the trial court, not merely per individual IST defendant. Here, the trial court made no specific findings on whether DSH committed separate violations on each day beyond the deadline. The case was remanded to permit the trial court to make any such findings in the first instance.

The full opinion is available on the court’s website here: https://www.courts.ca.gov/opinions/documents/C094784.PDF