People v. Arriola CA4/1

Discussion” (beginning, “Arriola claims the trial court . . . .”) , and replace with the following paragraphs: Arriola claims the trial court erred because it failed to state its findings on the record as required by California Rules of Court, rule 4.130. He also asserts Dr. Badre’s opinion held little evidentiary value when weighed against Arriola’s medical records, Dr. DeFrancesco’s testimony, and Ms. Marquez’s statements. According to Arriola, this evidence established that he could not assist in his defense and was, therefore, incompetent.

When competency is determined at a bench trial, “the court’s findings must be made in writing or placed orally in the record.” (Cal. Rules of Court, rule 4.130(e)(4)(B).) Here, the trial court discussed the evidence it considered, recited the applicable law, noted the dispute was focused on whether Arriola’s mental illness precluded him from assisting in his defense, found that Arriola failed to carry his burden on that issue, and explicitly stated Arriola was competent to stand trial. We find this a sufficient statement of the court’s findings. (See, e.g., People v. Marks (1988) 45 Cal.3d 1335, 1343 [stating “that no ‘magic words’ are…