People v. Goodrich
7 Cal. App. 5th 699
| Cal. Ct. App. | 2017Background
- In 2007 Goodrich pled guilty to felony grand theft (Pen. Code §487(c)), served 16 months, and upon release in 2008 was committed as a Mentally Disordered Offender (MDO) under §2962.
- MDO initial commitment in 2008 found all six statutory criteria satisfied (severe mental disorder, treatment history, crime related to disorder, sentence to and service of prison term, danger to others).
- Proposition 47 (Nov. 2014) created a mechanism (§1170.18) to redesignate certain felonies as misdemeanors and to recall/resentence eligible convictions; Goodrich petitioned under §1170.18(f) and the court redesignated his 2007 felony theft as a misdemeanor (People did not oppose).
- The People filed a separate petition in 2015 to recommit Goodrich as an MDO for another year; Goodrich moved to dismiss, arguing the redesignation eliminated the felony prerequisite for MDO status.
- The trial court denied dismissal, found the original 2008 commitment valid, and granted the recommitment; Goodrich appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Proposition 47 redesignation of the underlying conviction prevents annual recommitment as an MDO | People: Recommitment focuses on current mental condition; prior valid felony-based commitment remains intact | Goodrich: §1170.18(k) makes redesignation "for all purposes," so his underlying offense is no longer a felony and thus cannot support MDO commitment | Court: Affirmed — recommitment requires only current mental-disorder criteria; foundational felony requirement applied to initial commitment and was satisfied in 2008, so redesignation does not bar recommitment |
Key Cases Cited
- Lopez v. Superior Court, 50 Cal.4th 1055 (describing MDO Act purposes and distinguishing static vs. changeable commitment criteria)
- Harrison, People v. Harrison, 57 Cal.4th 1211 (explaining §2962 initial-commitment criteria and review process)
- Cobb, People v. Cobb, 48 Cal.4th 243 (noting recommitment focuses on current condition: disorder, remission status, and dangerousness)
- Acosta, People v. Acosta, 242 Cal.App.4th 521 (describing Proposition 47's purpose to reduce penalties for nonserious, nonviolent crimes)
- Shabazz, People v. Shabazz, 237 Cal.App.4th 303 (interpreting §1170.18 and its limited prospective/retroactive application)