People v. Miranda
236 Cal. App. 4th 978
| Cal. Ct. App. | 2015Background
- Miranda was charged with making criminal threats and resisting arrest after a 9/23/2013 incident involving police and a neighbor; the defense decided to proceed pro per after the public defender sought more time to prepare; Miranda’s self-representation was granted following a Faretta waiver executed at a December 2013 hearing; trial included testimony about Miranda’s bipolar/schizophrenic history and mental health treatment noncompliance; stand-by counsel remained available during trial and later sentencing; the court ultimately imposed a suspended prison term with probation and a mental health services condition; Miranda challenges the Faretta grant and trial handling of his mental health issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Faretta waiver was knowing, intelligent, and voluntary | Miranda | Miranda | Waiver valid; knowing, intelligent, voluntary. |
| Whether trial court erred by granting self-representation without considering Miranda’s mental health | People | Miranda | No reversible error; competent to represent himself. |
| Whether court should have inquired further about mental competence during trial | People | Miranda | No duty to conduct ongoing inquiry; no error under Edwards/Johnson. |
| Whether failure to give CALCRIM No. 358 (view admissions with caution) was reversible error | People | Miranda | Harmless error; no impact on result. |
Key Cases Cited
- Faretta v. California, 422 U.S. 806 (1975) (constitutional right to self-representation; need for knowing waiver)
- People v. Noriega, 59 Cal.App.4th 311 (1997) (requirement of knowing and intelligent waiver; overall record review)
- People v. Koontz, 27 Cal.4th 1041 (2002) (de novo review of waiver; discretionary denial allowed in certain mental-illness contexts)
- Johnson v. State (California Supreme Court), 53 Cal.4th 519 (2012) (trial court discretion to deny self-representation when severe mental illness prevents basic tasks)
- Edwards v. Indiana, 554 U.S. 164 (2008) (gray-area mentally ill defendants may be treated differently; higher standard permitted)
- Taylor, 47 Cal.4th 850 (2009) (discretion to deny self-representation under Edwards/Johnson; competent to stand trial not necessarily articulate)
- People v. Blair, 36 Cal.4th 686 (2005) (not required to question waiver form; silence on some advisements not fatal)
- People v. Stankewitz, 51 Cal.3d 72 (1990) (harmless error standard for instructional error where no conflict in evidence)
- Zichko v. California, 118 Cal.App.4th 1055 (2004) (in earlier rule about CALCRIM 358; later affected by Diaz decision)