People v. Murdoch
194 Cal. App. 4th 230
| Cal. Ct. App. | 2011Background
- Criminal proceedings against Murdoch were suspended under Pen. Code § 1368 for mental competency evaluation.
- Doctors found Murdoch had severe mental illness but was presently competent due to medication; he later refused medication.
- Experts warned decompensation and incompetence could occur if Murdoch continued to refuse treatment.
- The court initially found Murdoch competent and reinstated proceedings; later he sought and obtained self-representation, relieving counsel.
- Prior to trial, Murdoch advanced a bizarre defense that the victim was not human and involved questioning about shoulder blades.
- Evidence suggested Murdoch’s competence depended on continued medication, and he had stopped taking it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court erred in not ordering competency proceedings | Murdoch presented substantial evidence of incompetence due to medication noncompliance and decompensation risk. | Murdoch had been found competent on prior evaluations and chose self-representation; no substantial doubt mandated a competency hearing. | Yes; court erred by not conducting a § 1368 competency inquiry. |
Key Cases Cited
- People v. Lewis, 43 Cal.4th 415 (Cal. Supreme. 2008) (due process requires competency hearing with substantial evidence of incompetence)
- People v. Panah, 35 Cal.4th 395 (Cal. Supreme. 2005) (trial court must order competency hearing when doubt exists)
- People v. Jensen, 43 Cal.2d 572 (Cal. Supreme. 1954) (distinguishes that psychiatric diagnosis alone does not prove competence)
- People v. Kroeger, 61 Cal.2d 236 (Cal.2d. 1964) (bizarre conduct alone not determinative; context matters for competence)
- People v. Williams, 235 Cal.App.2d 389 (Cal.App. 1965) (isolated bizarre statements insufficient for competency finding)
- People v. Young, 34 Cal.4th 1149 (Cal. Supreme. 2005) (records must reflect doubt and trigger § 1368 inquiry)
- People v. Ary, 51 Cal.4th 510 (Cal. Supreme. 2011) (remand remedy for competency issues; reverse judgment when appropriate)
- People v. Merkouris, 52 Cal.2d 672 (Cal. Supreme. 1959) (definition of competence to stand trial)