People v. Morales CA2/7

DISCUSSION

I. Competency

Morales was twice found competent to stand trial. It is not entirely clear from his briefing whether Morales contends that both determinations were incorrect or that only the later determination was in error. In an abundance of caution, we address both rulings.

A. First Competency Determination

When there exists substantial evidence of incompetence, the trial court is required to declare a doubt and to conduct a full competency hearing. (People v. Koontz (2002) 27 Cal.4th 1041, 1064.) The court did so prior to trial, and then found Morales competent to stand trial. We review that decision based on the information available to the trial court at the time (People v. Panah (2005) 35 Cal.4th 395, 434, fn. 10), and we determine whether substantial evidence, viewed in the light most favorable to the determination, supports the trial court’s finding. (People v. Marshall (1997) 15 Cal.4th 1, 31 (Marshall).) The only evidence presented to the court at the first competency hearing was Chadha’s report, which the court observed was “very thorough,” based on “a comprehensive interview,” and “unequivocal” in its findings. Chadha concluded that Morales did not…