People v. Quiroz
244 Cal. App. 4th 1371
| Cal. Ct. App. | 2016Background
- Defendant Victor Quiroz was found incompetent to stand trial, committed to a state hospital, and remained confined for about three years during restoration attempts.
- The state hospital issued a final report certifying defendant remained incompetent and was "unlikely to regain competency in the foreseeable future," recommending conservatorship proceedings (no substantial likelihood certification).
- The public guardian declined to file a Murphy conservatorship petition after evaluating defendant, concluding he did not meet conservatorship criteria.
- The prosecutor requested a competency hearing challenging the hospital’s no-substantial-likelihood certification and asking the court to reconvene competency proceedings or reinstate charges.
- The trial court denied defendant’s motion to dismiss, held a competency hearing after the hospital’s certification, found defendant competent, and accepted a plea; defendant appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a trial court may convene a competency hearing after a state hospital issues a no-substantial-likelihood certification (or after three years’ commitment) | The People argued the court may redetermine competence upon defendant’s return and proceed if competency is found | Quiroz argued the court had no statutory authority to hold a competency hearing after the hospital’s no-substantial-likelihood certification and three-year commitment | Court held the statutes do not authorize a competency hearing at that point; convening one exceeded the court’s jurisdiction and reversed the judgment |
Key Cases Cited
- Jackson v. Indiana, 406 U.S. 715 (U.S. 1972) (indefinite commitment for incompetency without alternative procedures unconstitutional)
- In re Davis, 8 Cal.3d 798 (Cal. 1973) (limits on confinement duration and requirement to release or recommit under civil procedures)
- People v. Waterman, 42 Cal.3d 565 (Cal. 1986) (describes process when defendant is returned as unlikely to regain competence and court options)
- Conservatorship of Hofferber, 28 Cal.3d 161 (Cal. 1980) (discussed return and redetermination of competence after commitment)
- People v. Lawley, 27 Cal.4th 102 (Cal. 2002) (competency proceedings are special statutory proceedings)
- People v. Sakarias, 22 Cal.4th 596 (Cal. 2000) (competency-restoration certification and related hearing procedures)