People v. Lightsey
54 Cal. 4th 668
| Cal. | 2012Background
- Lightsey was convicted in Kern County for first degree murder, burglary, and robbery related to the murder, with special circumstances and a death sentence.
- The trial court permitted Lightsey to represent himself during competency proceedings, which were conducted in multiple rounds across 1994.
- Two psychiatrists and a third provided competing evaluations of Lightsey’s mental state, with disagreement over his competency to stand trial and his capacity to represent himself.
- Lightsey’s counsel and the prosecution both sought and the court conducted competency hearings under § 1368, including a subsequent court-ordered competency assessment.
- After inconsistent findings and repeated self-representation, the trial court declared Lightsey competent, then allowed self-representation through the guilt and penalty phases.
- The Court of Appeal later determined the trial court violated § 1368 by not appointing counsel during the second competency proceedings, and remanded for a retrospective competency hearing feasibility analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court err by not appointing counsel during the second § 1368 competency proceedings? | Lightsey | People | Yes; statutory error reversible; remand to determine retrospective competency feasibility. |
| May a court allow self-representation in competency proceedings when counsel is required by statute? | Lightsey | People | No; Edwards/Johnson framework permits counsel; self-representation improper during competency proceedings. |
| Is a limited remand for a retrospective competency hearing feasible to cure § 1368 violations? | Lightsey | People | Yes; limited remand feasible if retrospective hearing can be meaningfully conducted. |
| What is the proper remedy for the § 1368 error given the time and evidence available? | Lightsey | People | Remand with feasibility determination; if retrospective hearing feasible, conduct it; if incompetent, order new trial. |
Key Cases Cited
- Indiana v. Edwards, 554 U.S. 164 (U.S. 2008) (limits right to self-representation when mentally ill to ensure fair proceedings)
- Faretta v. California, 422 U.S. 806 (U.S. 1975) (right to self-representation but may be curtailed under certain conditions)
- Godinez v. Moran, 509 U.S. 389 (U.S. 1993) (standard for competence to plead or waive counsel aligns with Dusky)
- People v. Welch, 20 Cal.4th 701 (Cal. 1999) (duty to conduct full competency hearing when substantial doubt exists)
- People v. Ary, 118 Cal.App.4th 1016 (Cal. App. 2004) (limited remand for retrospective competency remedy for Pate error)
- People v. Johnson, 53 Cal.4th 259 (Cal. 2012) (limits on self-representation consistent with Edwards; Batson-like remand framework guidance)
- People v. Sharp, 7 Cal.3d 466 (Cal. 1972) (standard that defendant may not be deprived of representation in certain proceedings)
- United States v. Morrison, 449 U.S. 361 (U.S. 1981) (remedies for structural error should tailor relief to injury)