65 Cal.App.5th 1197
Cal. Ct. App.2021Background:
- Medina was charged in Nov 2016 and in June–Sept 2017 was adjudicated mentally incompetent to stand trial and to have a developmental disability; the court ordered commitment under former Penal Code §1370.1.
- The Regional Center of Orange County (RCOC) and DDS concluded Medina was ineligible for regional-center services and declined to recommend placement or treatment, producing a multi‑year stalemate in which Medina received little or no restoration treatment.
- Under the statutes in effect in 2017, a court finding of incompetence plus a finding of developmental disability suspended proceedings without requiring regional‑center concurrence; the statutory scheme governs when and how competence may be re‑determined.
- In July 2020 the trial court vacated the 2017 incompetency adjudication and ordered a new competency hearing, concluding the court lacked a placement remedy while treatment providers refused services.
- The Court of Appeal granted a writ in part: it held the trial court lacked statutory authority to vacate the incompetency/developmental‑disability orders (absent a certificate of restoration), reinstated the 2017 orders, and directed an evidentiary hearing to determine whether the maximum commitment period has elapsed, applying all custody days to the limit because Medina was denied the treatment he was entitled to.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| 1) Did the trial court have authority to vacate the 2017 incompetency/developmental‑disability findings and hold a new competency hearing? | Medina: court lacked statutory authority; redetermination requires a certificate of restoration or statutorily enumerated grounds. | DA/Trial court: prior incompetency order was interlocutory and subject to reconsideration; court must avoid an endless stalemate. | Held: Trial court lacked authority. No statute permits vacating an adjudication of incompetence for a defendant found developmentally disabled absent a certificate of restoration. |
| 2) Did the trial court exceed the scope of this Court's June 12, 2020 remand? | Medina: trial court exceeded remand by vacating the incompetency order. | Trial court/DA: remand did not divest trial court of jurisdiction to take further action. | Held: Vacating the incompetency order exceeded the specific remand directions, though the remand did not strip the trial court of all future jurisdiction in the ongoing case. |
| 3) Has Medina been denied due process by prolonged confinement without treatment and without accrual toward the maximum commitment? | Medina: because providers refused statutorily‑required services, all custody days since the commitment order should count toward the maximum commitment; otherwise due process violated. | DA: traditional rule credits only days actually spent in treatment facilities toward the maximum period. | Held: If the failure to provide treatment caused the delay, due process requires counting all custody days (jail/prison/treatment) since the commitment order toward the maximum commitment period. The court ordered a new hearing applying that rule. |
| 4) What remedy and next steps are required? | Medina: reinstate incompetency orders, vacate subsequent competency findings, and determine whether max commitment elapsed leading to dismissal/release. | DA: sought to reexamine competence and proceed to competency trial. | Held: Writ granted in part—trial court must reinstate the 2017 incompetency/developmental‑disability orders, vacate later competency findings and appointments, and within 60 days hold an evidentiary hearing (conclude within 15 days) to apply all custody days from Nov 22, 2017 toward the former §1370.1 maximum and then proceed per §1370.1(c). |
Key Cases Cited
- People v. DeLouize, 32 Cal.4th 1223 (Cal. 2004) (finality/interim‑order principles in criminal proceedings)
- In re Taitano, 13 Cal.App.5th 233 (Cal. Ct. App. 2017) (statutory scheme limits court authority to hold competency hearings)
- People v. Quiroz, 244 Cal.App.4th 1371 (Cal. Ct. App. 2016) (competency hearings permitted only where statute authorizes)
- Carr v. Superior Court (Carr I), 11 Cal.App.5th 264 (Cal. Ct. App. 2017) (treating‑facility officials may file a certificate of restoration before treatment is provided)
- People v. Carr (Carr II), 59 Cal.App.5th 1136 (Cal. Ct. App. 2021) (overview of the statutory competency‑restoration scheme)
- Jackson v. Indiana, 406 U.S. 715 (U.S. 1972) (due process limits on indefinite commitment of criminal defendants incompetent to stand trial)
- In re Davis, 8 Cal.3d 798 (Cal. 1973) (California adoption of Jackson principles)
- In re Albert C., 3 Cal.5th 483 (Cal. 2017) (Jackson/Davis do not prohibit legislatively prescribed maximum commitment terms)
- People v. G.H., 230 Cal.App.4th 1548 (Cal. Ct. App. 2014) (ordinary rule credits only time actually spent in treatment facilities toward statutory maximum)