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Name: People v. Hannibal
Case #: B187029
Court: CA Court of Appeal
District 2 DCA
Division: 6
Opinion Date: 10/10/2006

Appellant contended he was denied his constitutional and statutory right to represent himself in MDO proceedings. The court rejected the argument, finding that because MDO proceedings are civil in nature, there is no constitutional right to self-representation. The court did not commit prejudicial error when it denied appellant’s request to represent himself. The request to represent himself was not unequivocal, and the court did not abuse its discretion in concluding that appellant did not understand the complexity of the legal issues in the case. Further, appellant made no showing that it was more probable that he would have received a better result if he had represented himself. Appellant also argued that the trial court erred in concluding that the relitigation of his mental state at the time of his controlling offense, which was the subject of prior MDO proceedings, was not barred by res judicata and collateral estoppel. The appellate court rejected this argument as well, holding that the finding that appellant did not suffer from a severe mental disorder at the time of the prior proceeding was irrelevant to the determination of whether he was suffering from a severe mental disorder when he committed the controlling offense. Therefore the prosecution was not barred from establishing it in the instant proceeding.