People v. Johnson
136 Cal. Rptr. 3d 54
| Cal. | 2012Background
- Johnson was convicted of two assaults, including a brutal sexual assault on a Vallejo bartender and a separate assault at a sandwich shop.
- He initially represented himself after a July 5, 2007 request, with Judge Carter permitting self-representation through January 2008.
- By January 30, 2008, the court doubted Johnson’s competence to be tried due to bizarre behavior and letters, and ordered competency evaluations.
- Three mental health experts evaluated Johnson; two urged interviews were essential, while Johnson refused to meet with them.
- In October 2008, a jury found Johnson competent to stand trial, and the court reinstated his self-representation, which the court later questioned.
- Two days after the competency finding, the court revoked Johnson’s self-representation based on concerns akin to Edwards and appointed counsel to represent him for trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May California deny self-representation to gray-area defendants | Johnson should be allowed self-representation under Faretta | Edwards permits denial of self-representation for gray-area defendants | Yes, California may deny self-representation when Edwards permits denial |
| Was the Edwards-based denial proper in this case | Trial court properly applied Edwards to deny self-representation | Denial was erroneous or unsupported | Yes, denial was within trial court’s discretion and supported by record |
| What standard governs denial of self-representation under Edwards | A clear cognitive/communicative standard is required | A broader Burnett-style standard may apply | Court adopts a cautious Edwards-based standard focusing on severe mental illness preventing basic tasks for self-representation |
| Is Edwards retroactive or prospective in application | Edwards applies retroactively to Johnson’s case | Edwards applies prospectively | Edwards applied prospectively to post-decision proceedings |
Key Cases Cited
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (Sixth Amendment right to self-representation)
- Indiana v. Edwards, 554 U.S. 164 (U.S. 2008) (Permissive denial of self-representation for gray-area defendants)
- People v. Sharp, 7 Cal.3d 448 (Cal. 1972) (California law on self-representation before Faretta)
- People v. Floyd, 1 Cal.3d 694 (Cal. 1970) (Reason to deny self-representation based on youth/education/ignorance)
- People v. Taylor, 47 Cal.4th 850 (Cal. 2009) (Affirms Edwards framework and limits on self-representation discretion)
- People v. Burnett, 188 Cal.App.3d 1314 (Cal. App. 1987) (Cognitive/communicative skills standard for self-representation)
- Edwards (Indiana v. Edwards), 554 U.S. 164 (U.S. 2008) (Gray-area defendants may be denied self-representation)
- Taylor, 47 Cal.4th 850 (Cal. 2009) (California adoption of Edwards framework)
- Tapia v. Superior Court, 53 Cal.3d 282 (Cal. 1991) (Prospective application of new discipline rules)