People v. Samuelson CA4/1

DISCUSSION

Samuelson contends the trial court erred in ordering that she could be involuntarily

medicated with antipsychotic drugs. Because she has been restored to competency and is

no longer committed to Patton State Hospital, however, her challenge to the February 20,

2014, involuntary medication order is now moot.

" ' "[A]n action that originally was based on a justiciable controversy cannot be

maintained on appeal if all the questions have become moot by subsequent acts or events.

A reversal in such a case would be without practical effect, and the appeal will therefore

be dismissed." [Citation.]' " (People v. DeLong (2002) 101 Cal.App.4th 482, 486.)

In People v. Lindsey (1971) 20 Cal.App.3d 742, the trial court found the defendant

incompetent to stand trial and committed him to a state hospital for care. (Id. at p. 743.)

The defendant appealed the order of commitment. (Ibid.) While the appeal was pending,

however, the court received notice of the defendant's competency. (Ibid.) Emphasizing

the competency certification terminated the commitment and left no prejudicial

consequences that might be ameliorated by a successful appeal, the appellate…