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12 California opinions name it 3 courts 1988–2025 1 in the last five years
The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
People v. Younggreen2 sentences2018The failure to conduct a hearing despite the presence of such substantial evidence is reversible error"]; People v. Young (2005) 34 Cal.4th 1149 , 1216, 24 Cal.Rptr.3d 112 , 105 P.3d 487 [if a defendant produces substantial evidence of incompetence, " 'due process requires that a full competence hearing be held as a matter of right' " and the trial court has " 'no direction to exercise' "]; People v. Kaplan (2007) 149 Cal.App.4th 372 , 383, 57 Cal.Rptr.3d 143 [federal due process and state law require a trial court to suspend trial proceedings and conduct a mental competency hearing when the c 2018The failure to conduct a hearing despite the presence of such substantial evidence is reversible error"]; People v. Young (2005) 34 Cal.4th 1149 , 1216, 24 Cal.Rptr.3d 112 , 105 P.3d 487 [if a defendant produces substantial evidence of incompetence, " 'due process requires that a full competence hearing be held as a matter of right' " and the trial court has " 'no direction to exercise' "]; People v. Kaplan (2007) 149 Cal.App.4th 372 , 383, 57 Cal.Rptr.3d 143 [federal due process and state law require a trial court to suspend trial proceedings and conduct a mental competency hearing when the c | 1 | 2 |
People v. Kaplangreen2 sentences2018The failure to conduct a hearing despite the presence of such substantial evidence is reversible error"]; People v. Young (2005) 34 Cal.4th 1149 , 1216, 24 Cal.Rptr.3d 112 , 105 P.3d 487 [if a defendant produces substantial evidence of incompetence, " 'due process requires that a full competence hearing be held as a matter of right' " and the trial court has " 'no direction to exercise' "]; People v. Kaplan (2007) 149 Cal.App.4th 372 , 383, 57 Cal.Rptr.3d 143 [federal due process and state law require a trial court to suspend trial proceedings and conduct a mental competency hearing when the c 2018The failure to conduct a hearing despite the presence of such substantial evidence is reversible error"]; People v. Young (2005) 34 Cal.4th 1149 , 1216, 24 Cal.Rptr.3d 112 , 105 P.3d 487 [if a defendant produces substantial evidence of incompetence, " 'due process requires that a full competence hearing be held as a matter of right' " and the trial court has " 'no direction to exercise' "]; People v. Kaplan (2007) 149 Cal.App.4th 372 , 383, 57 Cal.Rptr.3d 143 [federal due process and state law require a trial court to suspend trial proceedings and conduct a mental competency hearing when the c | 1 | 2 |
Godinez v. Morangreen2 sentences2015(Godinez v. Moran (1993) 509 U.S. 389, 402 [ 113 S.Ct. 2680 ].) The California courts have not addressed whether the state constitutional due process clause (or right to counsel provision) requires a higher level of competency before a defendant may represent herself. 2015(Godinez v. Moran (1993) 509 U.S. 389, 402 [ 113 S.Ct. 2680 ].) The California courts have not addressed whether the state constitutional due process clause (or right to counsel provision) requires a higher level of competency before a defendant may represent herself. | 1 | 1 |
People v. Medinagreen2 sentences2012(See People v. Medina (1995) 11 Cal.4th 694, 735 [ 47 Cal.Rptr.2d 165 , 906 P.2d 2 ] [“[defendant's cursing and disruptive actions displayed an unwillingness to assist in his defense, but did not necessarily bear on his competence to do so . . .”].) Defense counsel at no time expressed any doubts about defendant’s understanding of the proceedings or his ability to assist in his defense. 2012(See People v. Medina (1995) 11 Cal.4th 694, 735 [ 47 Cal.Rptr.2d 165 , 906 P.2d 2 ] [“[defendant's cursing and disruptive actions displayed an unwillingness to assist in his defense, but did not necessarily bear on his competence to do so . . .”].) Defense counsel at no time expressed any doubts about defendant’s understanding of the proceedings or his ability to assist in his defense. | 1 | 1 |
People v. Rogersgreen2 sentences2012(People v. Ary, supra, 51 Cal.4th 510, 517 .) “A trial court’s decision whether or not to hold a competence hearing is entitled to deference, because the court has the opportunity to observe the defendant during trial.” (People v. Rogers (2006) 39 Cal.4th 826, 847 [ 48 Cal.Rptr.3d 1 , 141 P.3d 135 ].) Here, defendant’s disruptive courtroom behavior—throwing apples and saying “This is shit”—was evidence that he was angry and upset, and perhaps that he wished to interrupt the proceedings, but it was not evidence sufficient to require the trial court to conduct a mental competency hearing. 2012(People v. Ary, supra, 51 Cal.4th 510, 517 .) “A trial court’s decision whether or not to hold a competence hearing is entitled to deference, because the court has the opportunity to observe the defendant during trial.” (People v. Rogers (2006) 39 Cal.4th 826, 847 [ 48 Cal.Rptr.3d 1 , 141 P.3d 135 ].) Here, defendant’s disruptive courtroom behavior—throwing apples and saying “This is shit”—was evidence that he was angry and upset, and perhaps that he wished to interrupt the proceedings, but it was not evidence sufficient to require the trial court to conduct a mental competency hearing. | 1 | 1 |
James H. v. Superior Courtgreen2 sentences2011(James H. v. Superior Court (1978) 77 Cal.App.3d 169, 175 [ 143 Cal.Rptr. 398 ]; see also Citizens Utilities Co. v. Superior Court (1963) 59 Cal.2d 805, 812-813 [ 31 Cal.Rptr. 316 , 382 P.2d 356 ].) The single mental competency hearing ordered here avoided redundant litigation, the theoretical possibility of conflicting trial court rulings, unnecessary delay, and duplicative costs while preserving appellant’s right to have the question of his mental competency decided based on the evidence and the law. 2011(James H. v. Superior Court (1978) 77 Cal.App.3d 169, 175 [ 143 Cal.Rptr. 398 ]; see also Citizens Utilities Co. v. Superior Court (1963) 59 Cal.2d 805, 812-813 [ 31 Cal.Rptr. 316 , 382 P.2d 356 ].) The single mental competency hearing ordered here avoided redundant litigation, the theoretical possibility of conflicting trial court rulings, unnecessary delay, and duplicative costs while preserving appellant’s right to have the question of his mental competency decided based on the evidence and the law. | 1 | 1 |
Citizens Utilities Co. v. Superior Courtgreen2 sentences2011(James H. v. Superior Court (1978) 77 Cal.App.3d 169, 175 [ 143 Cal.Rptr. 398 ]; see also Citizens Utilities Co. v. Superior Court (1963) 59 Cal.2d 805, 812-813 [ 31 Cal.Rptr. 316 , 382 P.2d 356 ].) The single mental competency hearing ordered here avoided redundant litigation, the theoretical possibility of conflicting trial court rulings, unnecessary delay, and duplicative costs while preserving appellant’s right to have the question of his mental competency decided based on the evidence and the law. 2011(James H. v. Superior Court (1978) 77 Cal.App.3d 169, 175 [ 143 Cal.Rptr. 398 ]; see also Citizens Utilities Co. v. Superior Court (1963) 59 Cal.2d 805, 812-813 [ 31 Cal.Rptr. 316 , 382 P.2d 356 ].) The single mental competency hearing ordered here avoided redundant litigation, the theoretical possibility of conflicting trial court rulings, unnecessary delay, and duplicative costs while preserving appellant’s right to have the question of his mental competency decided based on the evidence and the law. | 1 | 1 |
People v. Medinagreen2 sentences2011As to who has the burden of proof on the question of the defendant’s mental competence, section 1369, subdivision (f), states in part: “It shall be presumed that the defendant is mentally competent unless it is proved by a preponderance of the evidence that the defendant is mentally incompetent.” Thus, under California law, when a trial court “prior to judgment” (§ 1368, subd. (a)) suspends criminal proceedings and holds a mental competency hearing, it is the defendant who bears the burden of establishing lack of competence (§ 1369, subd. (f); see People v. Medina (1990) 51 Cal.3d 870, 881 [ 2 2011As to who has the burden of proof on the question of the defendant’s mental competence, section 1369, subdivision (f), states in part: “It shall be presumed that the defendant is mentally competent unless it is proved by a preponderance of the evidence that the defendant is mentally incompetent.” Thus, under California law, when a trial court “prior to judgment” (§ 1368, subd. (a)) suspends criminal proceedings and holds a mental competency hearing, it is the defendant who bears the burden of establishing lack of competence (§ 1369, subd. (f); see People v. Medina (1990) 51 Cal.3d 870, 881 [ 2 | 1 | 1 |
People v. Samuelgreen2 sentences1994Discussion “It is a fundamental canon of criminal law, and a foundation of due process, that ‘A person cannot be tried or adjudged to punishment while such person is mentally incompetent.’ ” (People v. Samuel (1981) 29 Cal.3d 489, 494 [ 174 Cal.Rptr. 684 , 629 P.2d 485 ] [quoting Pen. 1994Discussion “It is a fundamental canon of criminal law, and a foundation of due process, that ‘A person cannot be tried or adjudged to punishment while such person is mentally incompetent.’ ” (People v. Samuel (1981) 29 Cal.3d 489, 494 [ 174 Cal.Rptr. 684 , 629 P.2d 485 ] [quoting Pen. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in California. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Elliott
green
1 sentence2025Defendant’s outbursts may have shown that he “was angry and upset, and perhaps that he wished to interrupt the proceedings, but it was not evidence sufficient to require the trial court to conduct a mental competency hearing.” (People v. Elliot (2012) 53 Cal.4th 535, 583 .) Critically, the record also contains more direct evidence that defendant’s outbursts were part of a calculated attempt to disrupt the proceedings. | 1 | 2025–2025 |
People v. Lindsey
green
1 sentence2015A reversal in such a case would be without practical effect, and the appeal will therefore be dismissed." ' " (People v. Delong (2002) 101 Cal.App.4th 482, 486 .) As established in People v. Lindsey (1971) 20 Cal.App.3d 742 (Lindsey), when a defendant is found to be mentally competent after he appeals an earlier finding of mental incompetency, a successful appeal of the earlier mental incompetency finding will no longer afford any 2 At the mental competency hearing after the trial court found Baker to be mentally incompetent, but before the trial court made a final decision on committing Baker | 1 | 2015–2015 |
People v. Delong
green
1 sentence2015A reversal in such a case would be without practical effect, and the appeal will therefore be dismissed." ' " (People v. Delong (2002) 101 Cal.App.4th 482, 486 .) As established in People v. Lindsey (1971) 20 Cal.App.3d 742 (Lindsey), when a defendant is found to be mentally competent after he appeals an earlier finding of mental incompetency, a successful appeal of the earlier mental incompetency finding will no longer afford any 2 At the mental competency hearing after the trial court found Baker to be mentally incompetent, but before the trial court made a final decision on committing Baker | 1 | 2015–2015 |
People v. Ary
green
1 sentence2012(People v. Ary, supra, 51 Cal.4th 510, 517 .) “A trial court’s decision whether or not to hold a competence hearing is entitled to deference, because the court has the opportunity to observe the defendant during trial.” (People v. Rogers (2006) 39 Cal.4th 826, 847 [ 48 Cal.Rptr.3d 1 , 141 P.3d 135 ].) Here, defendant’s disruptive courtroom behavior—throwing apples and saying “This is shit”—was evidence that he was angry and upset, and perhaps that he wished to interrupt the proceedings, but it was not evidence sufficient to require the trial court to conduct a mental competency hearing. | 1 | 2012–2012 |
Commonwealth v. Nieves
green
2 sentences2010(See, e.g., Commonwealth v. Nieves (2006) 446 Mass. 583 [ 846 N.E.2d 379 ]; State ex rel. 2010(See, e.g., Commonwealth v. Nieves (2006) 446 Mass. 583 [ 846 N.E.2d 379 ]; State ex rel. | 1 | 2010–2010 |
People v. Masterson
green
2 sentences2010(Masterson, supra, 8 Cal.4th at p. 969 .) It then went on to analyze the unique nature of competency proceedings as opposed to criminal and civil proceedings. 2010At the time of the jury trial, there were only 11 available jurors to try the case, and trial counsel stipulated with the People to have the case heard by an 11-person jury over his client's objection. ( Masterson, supra, 8 Cal.4th at pp. 967-968.) The Supreme Court granted review on the question whether "`the statutory right to a jury trial in a mental competency hearing pursuant to Penal Code sections 1368 and 1369 [is] subject to waiver over the objection of the defendant.'" ( Id. at p. 968.) [6] (4) The Masterson court first noted that there was no constitutional right to a jury trial in a | 1 | 2010–2010 |
Jones v. United States
green
2 sentences2010(See ibid , [initial sexually violent predator finding is "for present constitutional purposes, the functional equivalent of the NGI acquittal in Jones [v. United States (1983) 463 U.S. 354 [ 77 L.Ed.2d 694 , 103 S.Ct. 3043 ]]"; once a beyond-a-reasonable-doubt finding has been made in connection with initial commitment, the danger of an improper recommitment is "greatly diminished"].) We are well aware, as the People note, that several other jurisdictions have rejected a threshold mental competency requirement in sexually violent predator trials. 2010(See ibid , [initial sexually violent predator finding is "for present constitutional purposes, the functional equivalent of the NGI acquittal in Jones [v. United States (1983) 463 U.S. 354 [ 77 L.Ed.2d 694 , 103 S.Ct. 3043 ]]"; once a beyond-a-reasonable-doubt finding has been made in connection with initial commitment, the danger of an improper recommitment is "greatly diminished"].) We are well aware, as the People note, that several other jurisdictions have rejected a threshold mental competency requirement in sexually violent predator trials. | 1 | 2010–2010 |
Alaska Steamship Co. v. Petterson
green
1 sentence1988(See Pope v. United States (8th Cir. 1967) 372 F.2d 710 .) We distinguish Taylor v. Illinois, supra, 484 U.S. 400 [ 98 L.Ed.2d 798 ] and United States v. Nobles (1974) 422 U.S. 225 [ 45 L.Ed.2d 141 , 95 S.Ct. 2160 ], two cases employing evidentiary sanctions for the accused’s failure to comply with discovery rules, because both involve testimony of third party witnesses and neither concerns the question presented here of the defendant’s right not to discuss certain matters with the state. | 1 | 1988–1988 |
Duane Earl Pope v. United States
green
1 sentence1988(See Pope v. United States (8th Cir. 1967) 372 F.2d 710 .) We distinguish Taylor v. Illinois, supra, 484 U.S. 400 [ 98 L.Ed.2d 798 ] and United States v. Nobles (1974) 422 U.S. 225 [ 45 L.Ed.2d 141 , 95 S.Ct. 2160 ], two cases employing evidentiary sanctions for the accused’s failure to comply with discovery rules, because both involve testimony of third party witnesses and neither concerns the question presented here of the defendant’s right not to discuss certain matters with the state. | 1 | 1988–1988 |
United States v. Nobles
green
2 sentences1988(See Pope v. United States (8th Cir. 1967) 372 F.2d 710 .) We distinguish Taylor v. Illinois, supra, 484 U.S. 400 [ 98 L.Ed.2d 798 ] and United States v. Nobles (1974) 422 U.S. 225 [ 45 L.Ed.2d 141 , 95 S.Ct. 2160 ], two cases employing evidentiary sanctions for the accused’s failure to comply with discovery rules, because both involve testimony of third party witnesses and neither concerns the question presented here of the defendant’s right not to discuss certain matters with the state. 1988(See Pope v. United States (8th Cir. 1967) 372 F.2d 710 .) We distinguish Taylor v. Illinois, supra, 484 U.S. 400 [ 98 L.Ed.2d 798 ] and United States v. Nobles (1974) 422 U.S. 225 [ 45 L.Ed.2d 141 , 95 S.Ct. 2160 ], two cases employing evidentiary sanctions for the accused’s failure to comply with discovery rules, because both involve testimony of third party witnesses and neither concerns the question presented here of the defendant’s right not to discuss certain matters with the state. | 1 | 1988–1988 |
Taylor v. Illinois
green
1 sentence1988(See Pope v. United States (8th Cir. 1967) 372 F.2d 710 .) We distinguish Taylor v. Illinois, supra, 484 U.S. 400 [ 98 L.Ed.2d 798 ] and United States v. Nobles (1974) 422 U.S. 225 [ 45 L.Ed.2d 141 , 95 S.Ct. 2160 ], two cases employing evidentiary sanctions for the accused’s failure to comply with discovery rules, because both involve testimony of third party witnesses and neither concerns the question presented here of the defendant’s right not to discuss certain matters with the state. | 1 | 1988–1988 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.