People v. John Z.
223 Cal. App. 4th 1046
Cal. Ct. App.2014Background
- People filed a juvenile wardship petition under § 602 alleging John Z. attempted burglary in July 2012; John was 15 at the time.
- Counsel expressed a doubt about John's competency in November 2012, prompting a Welfare and Institutions Code § 709 suspension and appointment of an expert.
- Dr. Meshberg later concluded John had IQ 63 and was not competent, but his report was deemed lacking in detail by the court; further evaluation was needed.
- John admitted to misdemeanors in April 2013 after the district attorney offered to amend the petition, and the court questioned John on the record.
- John pled no contest to three misdemeanor counts on May 2, 2013 and the court adjudged him a ward of the court; disposition was nine months at a youth facility.
- John timely appealed on May 20, 2013, challenging competency procedures and related actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court had jurisdiction to withdraw the doubt about John's competency without a proper competency hearing. | People contends no due process violation; the court could accept counsel’s withdrawal. | John contends the withdrawal of doubt bypassed required § 709 hearing and expert input. | Yes, court lacked jurisdiction; competency hearing required and withdrawal void. |
| Whether the § 709 process required expert opinion before determining competency and admissibility of pleas. | People argues counsel’s assessment and on-record questioning sufficed. | John argues expert evaluation was essential for a valid competency determination. | Yes, expert input was required; reliance on on-record questioning alone was improper. |
| Whether John’s admissions to the misdemeanors were valid given potential incompetence. | Admissions supported by on-record questioning and counsel’s belief in ability to assist. | Admissions should be invalid if made while not presently competent. | Admissions invalid; must withdraw admissions and proceed under § 709. |
Key Cases Cited
- In re Gault, 387 U.S. 1 (U.S. 1967) (due process in juvenile proceedings established)
- People v. Pennington, 66 Cal.2d 508 (Cal. 1967) (right to competency hearing when substantial evidence of incompetence)
- Hale, 44 Cal.3d 531 (Cal. 1988) (once a competency hearing is ordered, proceeding cannot continue in absence of determination)
- Marks, 45 Cal.3d 1335 (Cal. 1988) (jurisdictional requirement of 1368 hearing cannot be waived by counsel)
- People v. Weaver, 26 Cal.4th 876 (Cal. 2001) (competency determinations central to plea process may rely on expert reports)