Jackson v. Superior Court of Riverside Cnty.
226 Cal. Rptr. 3d 110
| Cal. | 2017Background
- Jackson was found incompetent to stand trial in Riverside County and involuntarily committed under Penal Code §1370 for the statutory maximum (three years) but did not regain competence.
- Riverside County did not initiate an LPS (Murphy) conservatorship; Jackson was released after the §1370(c) period expired.
- Three days after release the DA obtained a superseding indictment (new case number) on the same charges and Jackson was rearrested under Penal Code §1387 (refiling after dismissal).
- The trial court declared a doubt as to competence and scheduled new competency proceedings; Jackson sought release and a writ, arguing he could not be rearrested or subjected to further competency commitment after serving the three-year §1370(c) maximum.
- The Supreme Court granted review to resolve whether refiling under §1387 and subsequent rearrest are permitted after a defendant has already been committed for the §1370(c) maximum, and if any further commitment is allowed.
Issues
| Issue | Jackson's Argument | Prosecution's Argument | Held |
|---|---|---|---|
| May prosecution dismiss and refile charges under §1387 and rearrest a defendant previously committed for three years under §1370(c)? | Refiling and rearrest are barred because the §1370(c) three-year commitment exhausted court power to detain for incompetence-related purposes. | §1387 permits one refiling; refiling restarts proceedings and rearrest is allowed. | Refiling and rearrest are permitted under §1387. |
| If rearrested and found incompetent again, may the court recommit the defendant for a new full §1370(c) period? | No — the three-year statutorily authorized limit applies across successive commitments, so no further commitment beyond the original maximum is permitted. | Court can order commitment for competence determination/treatment under §1368/§1370 after rearrest. | Recommitment is limited to the remaining balance (if any) of the original §1370(c) three-year period; if none remains, court must initiate LPS conservatorship if gravely disabled or release the defendant. |
| Does §1370(c) operate as a categorical bar to any further criminal proceedings after the three-year period expires? | Yes — release under §1370(c) should bar further proceedings on that charge. | No — §1368 applies "during the pendency of an action," and refiling under §1387 restarts proceedings; §1370(c) was not intended to be an absolute bar. | §1370(c) is not a categorical bar to further prosecution; refiling restarts proceedings but commitment limits carry forward. |
| Can the court hold a new competency hearing after refiling despite Quiroz authority? | Quiroz suggests courts lack statutory basis to retry competency after exhaustion of §1370(c). | Statutory basis exists because refiling + rearrest restart the action (§1368 applies); Quiroz addressed different facts. | A new competency hearing is permissible where refiling/rearrest provide the statutory basis, but detention pending such hearing must be reasonable and subject to §1370(c) aggregate limits. |
Key Cases Cited
- Jackson v. Indiana, 406 U.S. 715 (U.S. 1972) (constitutional limit: commitment solely for incompetence may not exceed reasonable period to determine likelihood of restoration)
- In re Davis, 8 Cal.3d 798 (Cal. 1973) (adopts Jackson rule of reasonableness for competence commitment)
- People v. Waterman, 42 Cal.3d 565 (Cal. 1986) (release required if defendant not gravely disabled after §1370 period)
- Crockett v. Superior Court, 14 Cal.3d 433 (Cal. 1975) (refiling under §1387 generally authorized; refiling cannot be used to defeat defendant rights)
- People v. Quiroz, 244 Cal.App.4th 1371 (Cal. Ct. App. 2016) (held court may lack statutory basis to hold a competency hearing in some post-§1370 scenarios; distinguished here)