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Name: Rodriguez v. Superior Court (2023) 15 Cal.5th 472
Case #: S272129
Court: CA Supreme Court
Opinion Date: 12/14/2023

For purposes of calculating the maximum commitment period for a defendant found incompetent to stand trial, the commitment continues past the filing of certificate of restoration and includes the time between such filing and the court’s decision whether to accept the certificate. Rodriguez was found incompetent to stand trial and committed to the Department of State Hospitals for treatment. The statutory scheme governing competency proceedings limits the term of commitment and, for individuals like Rodriguez charged with offenses that carry a maximum sentence exceeding two years, the commitment period is limited to two years. (See Pen. Code, § 1370(c)(1).) Following several months of treatment, the medical director filed a certificate of restoration with the trial court certifying that Rodriguez was restored to competency. The date for a contested hearing on Rodriguez’s competency and the trial court’s ruling on the certificate was continued several times due to the COVID-19 pandemic. Rodriguez eventually filed a motion to dismiss, arguing that his commitment had lasted more than the maximum two-year commitment period. The trial court denied the motion. The Court of Appeal denied Rodriguez’ petition for writ of prohibition. The California Supreme Court granted review to resolve a split in authority regarding when an incompetency commitment ends. Held: Reversed. The relevant statutes (§§ 1370(c)(1), 1372) do not explicitly state the point at which an incompetency commitment ends when a certificate of restoration has been timely filed. The Supreme Court examined the context, history, and purpose of the competency statutory scheme, analyzed the governing statutes, and concluded the commitment period continues through the trial court’s decision whether to accept the certificate. This interpretation “is consistent with the Legislature’s intent to limit the period of detention due to incompetency and provide certainty regarding the length of that detention period.” The court disagreed with the People’s numerous arguments that the period following the filing of a certificate of restoration should be excluded from the two-year maximum commitment period.

On remand, the Court of Appeal shall address remaining issues. The Supreme Court noted that it was only deciding the issue of statutory interpretation that was presented. On remand, the Court of Appeal shall consider whether the two-year limit of section 1370(c)(1) was exceeded in this case. To answer that question, the court may consider whether good cause continuances can toll the limit of section 1370(c)(1). If the court finds that the two-year statutory period has been exceeded, it shall further consider the nature of the remedy Rodriguez is entitled to at this point. The court should examine whether Rodriguez is entitled to dismissal of the charges pending against him or whether other relief (such as a Murphy conservatorship) is appropriate.