People v. Cuevas
213 Cal. App. 4th 94
| Cal. Ct. App. | 2013Background
- Ronald Cuevas, mentally retarded, was petitioned for involuntary commitment under former § 6500 for up to one year after a court found he was mentally retarded and dangerous.
- Petition filed March 15, 2011; commitment sought to CPT for up to one year.
- Trial held July 11, 2011; the People presented Dr. Walker and records; Ronald testified.
- Court found him mentally retarded and a danger to self or others; ordered one-year commitment.
- Appeals argued lack of causation between retardation and dangerousness; Barrett later held no jury-advice requirement; Sweeney/Bailie arguments on causation alleged.
- Court reverses commitment, finding no substantial evidence that retardation caused dangerousness under §6500.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §6500 require retardation to cause dangerousness | Ronald—causation required | People—no explicit causation requirement in statute | No substantial evidence of causation; reversal of commitment |
| Is there a due process requirement for jury trial/advice under Barrett | Ronald—due process requires jury trial | Barrett controls; no such requirement | Barrett controls; no due process violation in jury-right advisory |
| Is there a required dangerousness due to lack of self-control linked to retardation | Ronald—no explicit lack-of-control link needed | People—evidence supports link | No substantial evidence of a nexus; reversal; threshold for nexus insufficient |
Key Cases Cited
- People v. Barrett, 54 Cal.4th 1081 (Cal. 2012) (no requirement for jury-advice/personal waiver; discusses developmentally disabled protections)
- People v. Bailie, 144 Cal.App.4th 841 (Cal. Ct. App. 2006) (causation requirement in §6500 implied but later limited by Barrett)
- People v. Sweeney, 175 Cal.App.4th 210 (Cal. Ct. App. 2009) (held requirement that retardation causes serious difficulty in controlling dangerous behavior (causation))
- People v. Quinn, 86 Cal.App.4th 1290 (Cal. Ct. App. 2001) (statute does not expressly require causation between retardation and dangerousness)
- Howard N., 35 Cal.4th 117 (Cal. 2005) (extended detention; cognizance of lack-of-control in due process; used in SVP context)
- In re Howard N., 35 Cal.4th 117 (Cal. 2005) (discusses due process requirements for commitment extensions)
- Kansas v. Hendricks, 521 U.S. 346 (U.S. 1997) (upholds dangerousness plus mental abnormality/impairment linkage for SVP statutes)
- Kansas v. Crane, 534 U.S. 407 (U.S. 2002) (clarifies 'serious difficulty in controlling dangerous behavior' as threshold; rejects total lack of control requirement)
- O’Connor v. Donaldson, 422 U.S. 563 (U.S. 1975) (mental illness alone not enough for confinement if not dangerous)
- Foucha v. Louisiana, 504 U.S. 71 (U.S. 1992) (dangerousness plus mental illness not sufficient alone; requires current illness and danger)
- Williams, 31 Cal.4th 757 (Cal. 2003) (SVP procedural due process; Crane not forcing additional lack-of-control instructions)
- Lemanuel C., 41 Cal.4th 33 (Cal. 2007) (distinguishes LPS and non-SVP commitments; equal protection considerations)
- Carol K., 188 Cal.App.4th 123 (Cal. Ct. App. 2010) (limits lack-of-control concept in LPS context)