People v. Easter

Easter was charged with killing his wife. His attorney expressed doubts about his competency to stand trial. Proceedings were suspended while Easter was evaluated by medical professionals, one finding him competent to stand trial, the other finding him incompetent. Eight months after the evaluations, a jury found Easter competent. The homicide case resumed. Six months later, on the eve of trial, defense counsel again expressed doubt regarding Easter’s competency. Two judges declined to reinstate competency proceedings. The case proceeded, resulting in a verdict of guilty on the first-degree murder charge with a personal use of a firearm enhancement, a bench finding of guilty on a felon in possession of a firearm charge, and a sentence of 65 years to life in prison. The court of appeal reversed. The court erred in failing to reinstate competency proceedings. Counsel presented substantial evidence that Easter was experiencing new and worsened symptoms constituting a substantial change of circumstances in his mental condition. Counsel, having represented Easter since his arrest, described Easter’s recent communications as consisting of jumbled words and fanciful responses like Scrabble tiles tossed up and landing in random order. Easter could not hold a logical conversation, consult with counsel with a rational degree of understanding, assist in his own defense, or testify. “This is precisely the deficient mental state Penal Code section 1367 is aimed at addressing.” View "People v. Easter" on Justia Law