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Name: People v. Easter
Case #: A148197
Court: CA Court of Appeal
District 1 DCA
Division: 2
Opinion Date: 04/11/2019

Murder conviction reversed because trial court failed to reinstate competency proceedings despite evidence of defendant's worsened symptoms of mental illness, which prohibited him from assisting in his defense. Easter was charged with the murder of his wife. Prior to trial, defense counsel expressed a doubt about Easter's competency to stand trial. Criminal proceedings were suspended and a psychiatrist was appointed to examine Easter. The doctor found he was incompetent to stand trial. A psychologist appointed to give a second opinion concluded that Easter was competent to stand trial. A jury found him competent to stand trial and the criminal case…

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Name: People v. Rodas
Case #: S237379
Court: CA Supreme Court
District CalSup
Opinion Date: 11/26/2018

Where a criminal defendant had been restored to competence through medication, evidence the defendant was no longer taking the medication and was exhibiting signs of incompetence required a new competency hearing. Prior to his trial for three murders and two attempted murders, criminal proceedings against Rodas were suspended to conduct a competence examination. (Pen. Code, § 1368.) The doctors found appellant suffered from severe mental illness and he was committed to a state hospital. After several months of treatment, doctors found he was competent due to medication he had been given, and that he had to continue his medication to…

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Name: In re Sims
Case #: E069440
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 09/14/2018

After finding defendant competent to stand trial, trial court erred in not suspending proceedings during trial for further examination of defendant's competence based on her decompensated mental condition. Sims, a former attorney with longstanding mental illness, was charged with murdering her husband. After defense counsel declared a doubt about her competence to stand trial, a medical examiner deemed Sims competent but warned her condition could deteriorate if she continued to decline medication. The trial court found her competent. A few months later the trial court granted her Faretta motion and designated her retained attorney advisory counsel. Sims then moved to…

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Name: Anderson v. Gipson
Case #: 16-15338
Court: US Court of Appeals
District 9 Cir
Opinion Date: 09/06/2018

Petitioner entitled to federal habeas relief where his behavior at trial raised a "bona fide doubt" as to his competence to stand trial but the state trial court failed to order a competency hearing sua sponte. Anderson was convicted of spousal battery and other offenses in California after he assaulted his girlfriend. Prior serious felonies were found true and he was sentenced to 54 years to life under the Three Strikes law. His convictions were affirmed in state court and he exhausted his state remedies. He filed a federal writ petition challenging the trial court's failure to order a competency…

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Name: In re Galaviz
Case #: G055228
Court: CA Court of Appeal
District 4 DCA
Division: 3
Opinion Date: 05/18/2018

Trial court erred by not holding a second competency hearing when presented with evidence raising a serious doubt about whether defendant was competent to stand trial. In 1994, Galaviz was charged with assault and drug possession, with multiple enhancements. Prior to trial, the trial court found he was mentally incompetent to stand trial, suspended criminal proceedings, and committed him to the state hospital pursuant to Penal Code section 1368. In 1995, medical staff at the hospital reported that Galaviz had been restored to competency, but also reported that his condition was marginal and that a trial should be conducted quickly.…

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Name: People v. Johnson
Case #: C082890
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 03/13/2018

Trial court erred by refusing to hold a competency hearing pursuant to Penal Code section 1368 when faced with substantial evidence defendant was incompetent to stand trial. Appellant was charged with mayhem and other domestic violence crimes. Days before trial, his attorney expressed doubt about his competency to stand trial due to his erratic behavior in court and at the jail. The trial court refused defense counsel's multiple requests for a competency hearing pursuant to section 1368 based on the belief that appellant's behavior was merely a manipulative ploy to delay the proceedings. Appellant was placed on suicide watch at…

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Name: Jackson v. Superior Court (Riverside County)
Case #: S235549
Court: CA Supreme Court
District CalSup
Opinion Date: 12/11/2017

When a defendant found incompetent to stand trial does not regain competence and is released following a three-year involuntary commitment, he may be rearrested on charges that are refiled under Penal Code section 1387. Jackson was charged with sexual misconduct in Riverside County. The court declared a doubt as to his competency and suspended criminal proceedings. Jackson was ultimately declared incompetent to stand trial and committed to Patton State Hospital for up to the maximum term of three years (Pen. Code, § 1370), during which time he did not regain competence. Because he was not the subject of a conservatorship,…

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Name: Carr v. Superior Court
Case #: A147957
Court: CA Court of Appeal
District 1 DCA
Division: 3
Opinion Date: 04/28/2017

A defendant's competence to stand trial can be reassessed after he has been committed to the state hospital but before he has been transferred for treatment. The trial court found Carr incompetent to stand trial for murder and other offenses and committed him to a secure treatment facility. While he was awaiting transfer, the medical director of the Department of State Hospitals opined that Carr was malingering. Over Carr's objection, the court authorized a forensic psychiatrist to determine Carr's possible competence to stand trial. The psychiatrist opined that Carr was malingering and filed a declaration and certificate of competency. Thereafter,…

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Name: People v. Shiga
Case #: B256009
Court: CA Court of Appeal
District 2 DCA
Division: 7
Opinion Date: 11/29/2016

Defendant's arson conviction reversed where the trial court was unaware of its discretion to deny a "gray area" defendant's Faretta motion. Shiga set fire to a Catholic church and was charged with arson (Pen. Code, § 451.5, subd. (a)) and other offenses. Prior to trial three doctors evaluated his competence to stand trial. Two of the doctors found him competent while the third found him incompetent. After Shiga and his attorney disagreed about advancing a mental health defense, Shiga asked to represent himself. The prosecutor urged the trial court to conduct a separate evaluation of Shiga's mental competency to represent…

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Name: People v. Quiroz
Case #: C069280
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 02/23/2016

Trial court does not have authority to convene a competency hearing after the state hospital has found there is no substantial likelihood of restoration of competency. In 2008, a trial court found Quiroz incompetent to stand trial for assault with a deadly weapon and committed him to the state hospital for treatment. In 2010, the state hospital submitted its report stating Quiroz was still incompetent, was unlikely to regain competency in the foreseeable future, and recommended that conservatorship proceedings be initiated. The public guardian declined to file a conservatorship petition. Thereafter, the trial court held a competency hearing, found Quiroz's…

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