People v. Williams

This is an appeal from a judgment following a jury trial sustaining the People’s petition under Penal Code sections 2970 and 2972 to extend defendant Frank Williams’s commitment as a mentally disordered offender (MDO). The petition alleged that Williams had been convicted of assault with a deadly weapon (§ 245, subd. (a)(1)) in 1991 and assault with intent to commit rape (§ 220) in 1992, and that Williams, originally certified as an MDO in 1996, continued to suffer from a severe mental disorder that made him present a substantial danger of physical harm to other people. In February 2002, the jury found Williams to be an MDO and the court granted the People’s petition, extending Williams’s MDO commitment an additional year. This timely appeal follows.

Williams asserts that his MDO commitment must be reversed because the court denied his Faretta motion to represent himself at the trial on the MDO petition. The People respond by arguing that (1) the right to self-representation does not apply to an MDO commitment proceeding as it is a civil action; and (2) the court did not err in refusing to let Williams represent himself because Williams’s request to represent himself was…