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Name: People v. Williams
Case #: C076260
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 12/01/2015
Summary

Personality disorder not otherwise specified (NOS) can be a mental disease, defect, or disorder for purposes of extending a commitment under Penal Code section 1026.5. In 1993, Williams fired a machine gun and injured a police officer, and the next day shot at an officer and a police dog. The jury found him not guilty by reason of insanity of two counts of attempted murder and other offenses. He was committed to a state mental hospital (Pen. Code, § 1026), where he was diagnosed under the DSM-IV with alcohol and amphetamine dependence and personality disorder NOS. (Pen. Code, § 1026.) In 2013, the district attorney filed a petition to extend his commitment. At a bench trial, Dr. Deane, a psychiatrist, testified for the People that Williams had personality disorder NOS and, as a result of that mental disease, would pose a “really significant” danger if released without supervision. Citing People v. Superior Court (Blakely) 60 Cal.App.4th 202, Dr. Fennell, Dr. Deane’s boss, testified that personality disorder NOS does not meet the criteria for a mental disease, defect, or disorder under section 1026.5. The trial court found that Dr. Fennell’s interpretation of Blakely was misplaced and extended Williams’ commitment. Williams appealed. Held: Affirmed. Blakely holds that whether any alleged mental disease, defect, or disorder causes a person to represent a substantial danger of physical harm to others is not a question of law, but rather one for the trier of fact to be resolved with the assistance of expert testimony. Here, Dr. Fennell’s testimony regarding Blakely was simply wrong and the trial court properly relied on Dr. Deane’s testimony to find that Williams’ personality disorder NOS constitutes a “mental disease, defect, or disorder” that causes him to represent a substantial danger of physical harm to others, and that he has serious difficulty controlling his dangerous behavior.