People v. Woods CA2/7
B305662
| Cal. Ct. App. | Jun 29, 2021Background
- Defendant Lynn Rashaun Woods was convicted in 2012 of first-degree murder and related firearm offenses and sentenced to an aggregate term of 53 years 8 months to life.
- Woods represented himself at trial (Faretta) and testified; the prosecution presented eyewitness and forensic evidence linking the crime scene and a co-defendant to the murder.
- Woods had a long history of methamphetamine use and reported prior hallucinations; he later claimed he suffered a drug-induced toxic psychosis at the time of the offense and throughout trial.
- In September 2019 a prison psychologist (Dr. Ortigo) told Woods he likely had experienced toxic psychosis during the offense and trial; Woods then gathered records and filed a coram nobis petition in February 2020 seeking to vacate the conviction on grounds of legal insanity and incompetence to stand trial/represent himself.
- The superior court summarily denied the coram nobis petition for lack of substantial evidence of legal insanity or incompetence, and Woods appealed.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Woods) | Held |
|---|---|---|---|
| Whether coram nobis relief is warranted based on a postconviction claim that Woods was legally insane/drug-induced psychotic at the time of the offense and trial | The evidence is not new, Woods was aware of symptoms earlier, he was not diligent in presenting this before, and the petition fails to establish legal insanity or incompetence | Woods was suffering toxic psychosis during the offense and trial, newly diagnosed in 2019, and thus could not have presented an insanity defense or competently represent himself earlier | Denial affirmed: Woods failed to show new evidence or diligence; trial record and prior evaluations did not support a prima facie showing of legal insanity or incompetence |
| Whether the court erred by summarily denying the petition without appointing counsel or holding a hearing | No error: appointment of counsel and a hearing are required only if petitioner makes a prima facie showing; the petition did not meet that threshold | Court should have appointed counsel and held a hearing because the allegations, if true, could entitle Woods to coram nobis relief | Denial affirmed: no prima facie showing; summary denial and refusal to appoint counsel were proper |
Key Cases Cited
- People v. Shipman, 62 Cal.2d 226 (1965) (coram nobis may lie where defendant was in toxic psychosis and unable to raise insanity at trial)
- People v. Kim, 45 Cal.4th 1078 (2009) (coram nobis requirements and limits; cannot raise ineffective-assistance claims or errors of law)
- People v. Adamson, 34 Cal.2d 320 (1949) (coram nobis is narrow remedy for facts not presented at trial)
- In re Lindley, 29 Cal.2d 709 (1947) (coram nobis cannot be used to relitigate adjudicated factual issues)
- In re Clark, 5 Cal.4th 750 (1993) (right to counsel in postjudgment proceedings attaches only after prima facie showing)
- People v. Goodspeed, 223 Cal.App.2d 146 (1963) (presumption of validity of conviction in coram nobis proceedings)
- Faretta v. California, 422 U.S. 806 (1975) (defendant's right to self-representation)