196 Cal. App. 4th 801
Cal. Ct. App.2011Background
- Defendant Reynolds appealed a July 6, 2010 trial court order finding him incompetent to stand trial and ordering commitment to Patton State Hospital under Penal Code section 1370.2.
- He contends the court violated equal protection by not applying precommitment custody credits to the three-year commitment limit under section 1370, subdivision (c)(1).
- Defendant was initially placed at Patton from May 30, 2008, to July 22, 2009, after being found incompetent regarding arson and assault charges.
- In 2010 the court again found him incompetent, determined he had not exceeded the three-year maximum, and initiated conservatorship proceedings only to later disagree about the duration.
- At the July 6, 2010 placement hearing, the court again ordered commitment to Patton under 1370, calculating time served as 1,001 days plus 408 days of custody credit.
- Banks and related authorities were invoked to analyze whether precommitment credits could or should affect the three-year cap for commitments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether precommitment custody credits apply to the 3-year commitment cap | Banks requires credit against maximum term. | Credit must be applied to 3-year term under equal protection. | No equal protection violation; credits not deducted for 3-year commitment. |
| Is Banks distinguishing due to different maximum terms (three years vs maximum sentence) | Precommitment credits should reduce the term under Banks logic. | Distinct statutory maximum; Banks does not apply. | Banks inapplicable; three-year limit governs, not maximum sentence. |
| Whether Callahan supports deducting custody credits from the 3-year commitment term | Callahan supports credit deduction in some contexts. | Callahan concerns a different scenario (insanity commitment on a new charge). | Callahan distinguishes and does not compel deduction here; no error. |
| Whether the three-year period under 1370 applies to aggregate commitments for the same charges | Bank-like aggregation affects duration. | Analysis centers on three-year cap; not tied to indigency equity. | Three-year cap applies to aggregate incompetency commitments; no credit deduction. |
Key Cases Cited
- In re Banks, 88 Cal.App.3d 864 (Cal. App. Dist. 4th) (equal protection for precommitment custody credits under 1370)
- Callahan, 144 Cal.App.4th 678 (Cal. App. Dist. 2) (credit deduction in insanity commitment context distinct from instant case)
- People v. Karriker, 149 Cal.App.4th 763 (Cal. App. 4th Dist., Div. 2) (maximum duration for incompetency treatment; impact on Murphy conservatorship)
- In re Polk, 71 Cal.App.4th 1230 (Cal. App. 4th Dist.) (three-year period applies to aggregate commitments)
- People v. Waterman, 42 Cal.3d 565 (Cal. 1986) (purpose of 1370 is restoration of mental state for proceeding)
- Medina v. California, 505 U.S. 437 (U.S. Supreme Court, 1992) (due process and competency focus in hearings)