California v. Jackson

Patrick Jackson appealed his conviction and sentence for one count of lewd contact with a minor, arguing the trial court erroneously found him competent to stand trial before taking his guilty plea and again before sentencing him. Numerous psychologists found him incompetent to stand trial and unlikely to be restored to competency because he suffered from a stable developmental disability which limited his capacity for understanding and communication. Hospital staff “drilled” Jackson until he could answer simple, concrete questions about the judicial system. As a result, in February 2010, the trial court found Jackson competent based on the staff report, then accepted his guilty plea. Before he could be sentenced, new psychological evaluations reported Jackson denying his guilt and not understanding he had pled guilty. The new report also questioned the basis of the report finding him competent. In June 2010, the trial court found substantial evidence Jackson was incompetent. Over a year later, and in the face of additional evaluations finding Jackson incompetent and unlikely to improve, the trial court again found Jackson was competent and sentenced him to three years in state prison. This time, the court based the competency finding on the contents of an evaluation Patton State Hospital staff had prepared nearly nine months earlier which simply copied the analysis from its early 2010 “drilling” report and failed to address any of the concerns raised thereafter. On appeal, Jackson argued neither his conviction nor his sentence should stand because neither competency finding was based on substantial evidence. The Court of Appeal agreed and therefore reversed the judgment. View "California v. Jackson" on Justia Law