People v. Johnson, No. S188619, 2012 WL 254856 (Cal. Jan. 30, 2012)

Facts: Defendant Johnson was convicted of two assault crimes.  Defendant originally was represented by counsel but asked to represent himself.  The trial judge was concerned about his competence to stand trial and to defend himself.  Defendant refused to meet with experts to help determine his competency.  Without observing him, three psychiatrists had difficulty coming to a solid conclusion about his ability to stand trial.

The trial judge determined that Defendant was competent to stand trial, but not competent to represent himself.  The trial court convicted Defendant and the Court of Appeal affirmed.

Issue: Should trial courts deny self-representation due to mental health concerns when the defendant is determined to be mentally competent to stand trial?

Holding: Yes.  Trial courts may deny self-representation at trial due to mental health concerns when defendant is determined to be mentally competent to stand trial.

In the instant case, defendant was deemed competent to stand trial, but not competent to represent himself during the proceedings.

Reasoning: Indiana v. Edwards, 128 S. Ct. 2379 (2008) set forth that judges may insist that an individual who is deemed mentally fit to stand trial be prevented from representing himself at trial.  There is a distinction made between being fit to stand trial and being fit to provide self-representation.  Adopting this standard comports with California law.

The standard for making this determination is “whether the defendant suffers from a severe mental illness to the point where he or she cannot carry out the basic tasks needed to present the defense without the help of counsel.”  A trial court need only make this determination if it feels that there are doubts about the defendant’s mental competence.  A trial court may not deny self-representation simply because it believes the matter could be settled more efficiently or fairly.

By: Joshua Goodman

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