People v. R.V.
61 Cal. 4th 181
Cal.2015Background
- 16-year-old R.V. was detained after threatening family with a knife and charged under Welf. & Inst. Code § 602; defense counsel raised doubt about his competency.
- The juvenile court found substantial evidence of doubt, suspended proceedings, and appointed forensic psychologist Haig J. Kojian, Ph.D., to evaluate competency under § 709.
- Dr. Kojian’s report and testimony concluded R.V. was not competent: observed confusion, impaired thinking, mood disorder, school records showing low cognitive scores, and refusal to undergo full testing.
- The juvenile court rejected Dr. Kojian’s opinion, finding R.V. competent and citing the expert’s failure to complete malingering testing and certain statements by R.V. suggesting some understanding; R.V. then waived rights and was adjudicated a ward.
- The Court of Appeal affirmed; the California Supreme Court granted review and reversed, holding the juvenile court could not reasonably reject the expert’s well-supported opinion of incompetence.
Issues
| Issue | Plaintiff's Argument (R.V.) | Defendant's Argument (Attorney General) | Held |
|---|---|---|---|
| Whether § 709 implies a presumption of competency and places burden on minor to prove incompetence by preponderance | § 709 is silent so no presumption; burden should rest on neither or on prosecution after a prima facie showing | § 709 incorporates the adult scheme by implication; minor is presumed competent and bears burden to prove incompetence by a preponderance | Held: § 709 contains an implied presumption of competency; the party asserting incompetence bears the burden by preponderance |
| Standard of appellate review for sufficiency of evidence of juvenile competency under § 709 | De novo review because juvenile proceedings rely mainly on documentary/expert reports, making appellate review appropriate | Deferential substantial-evidence review, analogous to adult competency reviews | Held: Deferential substantial-evidence test applies; appellate court asks whether the evidence was such that the juvenile court could not reasonably reject it |
| Application of substantial-evidence test where only court-appointed expert opines incompetence | The expert’s uncontradicted, detailed opinion should compel a finding of incompetence | Even if prosecution presents no contrary evidence, court may reject expert opinion for reasoned grounds; review asks whether rejection was reasonable | Held: On this record (thorough, unequivocal expert opinion based on interviews and records), the juvenile court could not reasonably reject the expert’s conclusion; reversal required |
| Role of expert evidence and whether court should defer to expert or appoint second expert when methodology questioned | Once an expert is appointed under § 709, their specialized opinion merits substantial weight and court should defer or obtain additional expert evaluation if concerns exist | Expert opinion is not dispositive; trier of fact may reject expert after assessing reasoning and materials | Held: Expert opinion is highly significant under § 709, but not binding; if court finds methodological/ reasoning flaws in a sole expert report, appointing a second expert is a prudent step; here the court’s rejection was unreasonable |
Key Cases Cited
- Dusky v. United States, 362 U.S. 402 (1960) (constitutional standard for competency to stand trial: present ability to consult with counsel and rational/factual understanding)
- In re Gault, 387 U.S. 1 (1967) (juveniles entitled to essentials of due process in delinquency proceedings)
- People v. Medina, 51 Cal.3d 870 (1990) (Penal Code competency procedures and presumption of competency for adults)
- People v. Samuel, 29 Cal.3d 489 (1981) (competency-review principles and limitation on acceptance of expert opinion)
- People v. Drew, 22 Cal.3d 333 (1978) (formulation of substantial-evidence inquiry when experts unanimously opine to insanity)
- People v. Rells, 22 Cal.4th 860 (2000) (presumption of competency operates to place burden on party asserting incompetence)