People v. Rodas, 239 Cal. Rptr. 3d 814

Background

Domingo Rodas (aka Doudley Brown) charged with multiple murders and attempted murders; DNA and ID evidence supported prosecution.
Rodas had a long history of schizophrenia, prior findings of incompetence, and previous state-hospital confinement; experts concluded antipsychotic medication restored competence but warned competence depended on continued medication.
In May 2013 the court reinstated proceedings after receiving a hospital certification of competency that emphasized the need to remain medicated; no full evidentiary hearing occurred and no court order ensured ongoing medication at jail.
In March 2014, after jury selection, defense counsel told the court Rodas had stopped taking medication, was again speaking in incoherent “word salad,” insisted on testifying contrary to counsel’s advice, and could not coherently discuss defense strategy—counsel declared a doubt about competence.
The trial court conducted a brief colloquy in open court in which Rodas identified the charges, said he would cooperate, and stated he was not taking medication; the court declined to suspend the trial and proceeded; Rodas’s testimony was incoherent and struck as irrelevant.
The jury convicted Rodas; the Supreme Court held the trial court erred in not suspending proceedings to hold a competency hearing given the changed circumstances (medication cessation and relapse) and reversed the conviction; remand for retrial permitted if defendant is competent.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by refusing to suspend proceedings and order a competency hearing after defense counsel declared a doubt in March 2014	The evidence counsel described did not necessarily constitute substantial evidence of incompetence; Rodas’s in-court responses showed understanding of charges and willingness to assist, so no new hearing required	Counsel’s in-camera report plus defendant’s stopping medication and relapse into incoherent speech raised a reasonable doubt and required suspension and formal competency proceedings	Court held error: when prior competency was medication-dependent, proof defendant stopped meds and relapsed generally constitutes a substantial change of circumstances requiring a competency hearing under Pen. Code §1368 and due process
Whether a brief colloquy with defendant can substitute for a competency hearing when counsel raises a doubt	Colloquy showed defendant’s factual understanding and willingness to assist, which the trial court could rely on	Colloquy did not address the specific concern of inability to rationally assist counsel; Pate/ Pennington require formal inquiry when substantial evidence of incompetence appears	Court held colloquy insufficient to dispel substantial evidence of incompetence; formal inquiry required
Whether the appellate remedy should be a retrospective competency hearing or automatic reversal/remand	AG: remand for retrospective competency hearing to determine if defendant was competent at trial	Rodas: retrospective hearing would be infeasible; error warrants reversing conviction and allowing retrial only if currently competent	Court held retrospective competency hearing would not be feasible or reliable under these facts; reversed convictions and allowed retrial if defendant is presently competent
Whether prior certification of competence may be relied on absent a substantial change of circumstances	Prior finding stands unless new evidence or substantial change casts doubt	Defendant argued the cessation of medication and relapse was such a change	Court reiterated that prior findings can be relied upon, but when competence was achieved by medication, stopping meds and relapse generally constitutes a substantial change requiring new proceedings

Key Cases Cited

Pate v. Robinson, 383 U.S. 375 (1966) (substantial evidence of incompetence requires suspension and hearing; colloquy alone cannot substitute)
Drope v. Missouri, 420 U.S. 162 (1975) (difficulty and limits of retrospective competency determinations)
People v. Pennington, 66 Cal.2d 508 (1967) (state law follows Pate; substantial evidence of incompetence triggers hearing)
People v. Jones, 53 Cal.3d 1115 (1991) (prior competency finding may be relied on absent substantial change or new evidence)
People v. Rogers, 39 Cal.4th 826 (2006) (trial court duty to hold competency hearing when reasonable doubt arises)
People v. Lightsey, 54 Cal.4th 668 (2012) (discusses remedies and feasibility issues for retrospective competency hearings)
People v. Murdoch, 194 Cal.App.4th 230 (2011) (stopping medication plus delusional defense theory required new competency proceedings)
People v. Ary, 51 Cal.4th 510 (2011) (discusses feasibility standard for retrospective competency hearings)