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Name: People v. McDuffie
Case #: A111738
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 10/25/2006

The trial court suspended proceedings in McDuffie’s trial for armed robbery pursuant to Penal Code section 1368, and he was found incompetent to stand trial. A psychiatrist was appointed to determine whether it would be appropriate to forcibly administer psychotropic drugs in order to render McDuffie competent to stand trial. A hearing was held on the issue, and the court concluded that administration of medication would be substantially likely render McDuffie competent to stand trial. The court ordered McDuffie committed to Napa State Hospital and authorized the involuntary administration of antipsychotic medications. The court stayed its order while McDuffie appealed. The appellate court reversed the order. The court’s order was in error because there was not substantial evidence that forcible administration of the drugs would be substantially likely to render him competent to stand trial. The evidence showed that McDuffie had a fifty percent chance of improving with drugs, but the possibility was even smaller due to McDuffie’s history of not responding well to treatment. This was not enough to support the trial court’s finding that the drugs were substantially likely to render McDuffie competent.