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Name: People v. Haynie
Case #: F043306
Court: CA Court of Appeal
District 5 DCA
Opinion Date: 03/18/2004

Haynie appealed from an order extending his commitment to Napa State Hospital pursuant to Penal Code section 1026.5, which authorizes extended commitment for a person found not guilty by reason of insanity under section 1026. At his jury trial, and over his objection, the prosecutor called Haynie to testify in its case-in-chief. He admitted during his testimony that when he had been released from the hospital in the past, he quit taking his medications and had to be returned. The jury found that Haynie had a mental disorder and by reason of that represented a substantial danger to others. His commitment was extended two more years. On appeal, Haynie argued that he should not have been compelled to testify because it forced him to incriminate himself in violation of the constitutional privilege. The appellate court agreed and reversed the judgment. Haynie was entitled to the same rights afforded a criminal defendant, and therefore should not have been compelled to testify in the prosecution’s case. Further, the right to not be compelled to testify against oneself is implicated when a person is called by the state to testify in a proceeding to recommit him even if what is said on the witness stand is not per se incriminating.