Inland Counties Regional Center, Inc. v. Superior Court of Riverside County
10 Cal. App. 5th 820
| Cal. Ct. App. | 2017Background
- Defendant Adan Omar Barajas was charged with felonies, pled guilty to some counts, later alleged to have violated probation; competency concerns arose after a 2016 competency evaluation by a court-appointed psychologist found he lacked competence and suggested possible cognitive impairment.
- The trial court suspended proceedings under Penal Code § 1368–1369 and ordered Inland Counties Regional Center (IRC) to determine whether Barajas was incompetent due to a developmental disability and to provide a report by a court-ordered date.
- IRC refused to perform a full competency evaluation before completing its own eligibility assessment for developmental disability, explaining regional centers evaluate eligibility and services under the Lanterman Act and require steps and records to assess developmental disability.
- The trial court held IRC in contempt for failing to produce a competency evaluation, imposed $1,000 in sanctions (stayed for 14 days), and IRC petitioned for a writ of mandate to vacate the contempt order.
- The Court of Appeal concluded the order requiring IRC to perform a full competency evaluation was invalid because IRC had not yet determined Barajas was developmentally disabled and Penal Code § 1369(a) contemplates a more limited role for the regional center director (an examination and placement recommendation), so the contempt finding was annulled.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court validly ordered IRC to perform a full competency evaluation under Penal Code § 1369(a) | Court: §1369(a) permits appointing the regional center director to examine defendants suspected to be developmentally disabled and thus to perform competency evaluation | IRC: Regional centers must first determine eligibility for developmental disability and their role is to assess for developmental disability—not to supplant court-appointed psychiatrists/psychologists for competency evaluations | Held: Order invalid. §1369(a) permits regional center examination and placement recommendation but does not authorize ordering a full competency evaluation before eligibility is established |
| Whether contempt was justified for IRC’s noncompliance | Court: IRC failed to obey a clear order and ignored court direction | IRC: Reasonable dispute over statutory scope and duty; IRC lacked authority to do full competency evaluation without first establishing developmental-disability eligibility | Held: Contempt was an abuse of discretion; contempt reversed because order was not a valid, unambiguous order |
| Role and expertise of regional centers vs psychiatrists/psychologists in competency proceedings | Court: Leonard requires expertise when defendant is developmentally disabled; regional center expertise can be appropriate | IRC: If developmental disability is not established, regional center expertise may be inapplicable; psychiatrists/psychologists handle competency assessments | Held: Leonard does not support ordering IRC to perform full competency evaluations before eligibility is determined; regional center role is narrower |
| Whether administrative timelines (Welf. & Inst. Code) govern the timing of court-ordered assessments | IRC: Administrative timelines apply to regional center eligibility assessments | Barajas: Court process/timeline governs competency proceedings; disputed | Held: Court did not decide; unnecessary to resolve for this writ—limited ruling vacating contempt order only |
Key Cases Cited
- People v. Leonard, 40 Cal.4th 1370 (Cal. 2007) (discusses appointment and role of regional center director when a defendant is developmentally disabled)
- In re Marcus, 138 Cal.App.4th 1009 (Cal. Ct. App. 2006) (elements and required clarity of an order to support contempt)
- Chula v. Superior Court, 109 Cal.App.2d 24 (Cal. Ct. App. 1952) (scope of review in writ proceedings attacking contempt and jurisdictional facts)