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Name: People v. Koontz
Case #: S036450
Court: CA Supreme Court
District CalSup
Opinion Date: 05/09/2002
Subsequent History: Rehrg. den. 7/12/02

In this automatic appeal, appellant contended that his conviction was obtained in violation of his right to due process because he was not competent to stand trial and the trial court did not hold a hearing, pursuant to section 1368 on the issue of his competency. Appellant represented himself, and the record reflected "incoherent ramblings," an irrational defense of self-defense based on a nonexistent knife, and numerous witnesses who were either not helpful or damaging to the defense. The Court here affirmed. The record did not show that appellant lacked an understanding of the nature of…

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Name: Odle v. Woodford
Case #: 99-99029
Court: US Court of Appeals
District 9 Cir
Opinion Date: 02/06/2001
Subsequent History: Cert. den. 10/1/01

Here Odle had suffered massive trauma to his brain, and doctors had removed a grapefruit sized portion of his brain. Odle had also subsequently exhibited psychotic behavior, some of it while awaiting trial. Under these circumstances, the evidence before the trial court raised a bona fide doubt whether Odle was competent to stand trial, and inquiring into whether he possessed the mental acuity to participate in the proceedings was the reasonable and appropriate course of action. The state trial court's failure to do so denied Odle his right to due process. The Court of Appeals remanded…

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