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Name: People v. Jackson
Case #: E065757
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 04/17/2018

Trial court’s finding that defendant was competent to stand trial at the time of his plea and at sentencing was not supported by substantial evidence. Jackson was charged with lewd acts on a minor in San Bernardino County. A doubt was declared as to his competency and criminal proceedings were suspended. Jackson was declared incompetent to stand trial and committed to Patton State Hospital (Pen. Code, § 1370). The hospital staff found he suffered from mild mental retardation, had a limited capacity to understand legal proceedings, and was unlikely to become competent. However, hospital staff changed their mind in one evaluation after drilling Jackson until he could answer simple, concrete questions about the legal system. Relying on a report to this effect months after it was prepared, the trial court found Jackson competent and took his guilty plea. Prior to sentencing he was again found to be incompetent and committed to Patton. Over a year later, in the face of evaluations finding Jackson incompetent and unlikely to improve, the trial court found him competent and sentenced him. On appeal, he challenged the competency findings. Held: Reversed. The due process clause of the Fourth Amendment prohibits criminal prosecution of an incompetent person, i.e., one who lacks an ability to effectively consult with his attorney and to understand the nature of the proceedings against him. Both federal due process and state law require a trial court, when presented with evidence that raises a reasonable doubt as to the defendant’s competence, to suspend criminal proceedings, appoint a doctor to evaluate the defendant, and conduct a competency hearing. Here, the trial court’s findings that Jackson was competent were unsupported, since virtually all of his evaluations concluded he was mildly mentally retarded with very limited ability to understand legal concepts. The one report which stated he had a rote comprehension of basic legal concepts did not constitute substantial evidence of competency, and in any event was months old when the trial court relied upon it to find Jackson competent. This did not provide a sound basis for the court’s conclusion.

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