People v. Thompson CA3

BACKGROUND

We begin with a brief discussion of Edwards, and then discuss the facts of this case. Edwards involved three separate cases that were consolidated on appeal. (Edwards, supra, 88 Cal.App.5th at p. 1262.) In each case, the trial court found a criminal defendant was incompetent to stand trial and ordered that he or she be admitted to DSH for treatment.1 When DSH failed to admit the defendants in a timely manner, the trial court issued an order to show cause why sanctions should not be imposed and directed DSH to admit each defendant by a particular date. When the defendants were not admitted by that date, the trial court imposed sanctions of $1,000 for each day past the deadline, for a total of $91,000. (Edwards, at pp. 1264-1266.) DSH appealed all three sanctions orders, arguing they failed to comply with Code of Civil Procedure section 177.5,2 which provides: “A judicial officer shall have the power to impose reasonable money sanctions, not to exceed fifteen hundred dollars ($1,500), . . . for any violation of a lawful court order by a person, done without good cause or substantial justification. . . . [¶] . . . An order imposing sanctions shall be in writing and shall…