People v. Coleman CA1/1

DISCUSSION

Competency A defendant is incompetent to stand trial, if “as a result of a mental disorder or developmental disability, the defendant is unable to understand the nature of the criminal proceedings or to assist counsel in the conduct of a defense in a rational manner.” (§ 1367, subd. (a).) Trial of an incompetent defendant violates both state and federal due process guarantees. (People v. Smith (2003) 110 Cal.App.4th 492, 499; see U.S. Const., 14th Amend.; Cal.

2All further statutory references are to the Penal Code unless otherwise indicated. The District Attorney also filed a subsequent petition to revoke defendant’s probation after defendant: twice “[f]ailed to sign a Mental Health Release of Information/Consent” as directed; and “[s]ubmitted a positive drug test” for methamphetamine. The sentence consisted of the upper four-year term for the felony infliction of corporal injury on a spouse/cohabitant count and a three-year upper term for the felony false imprisonment count, which was stayed pursuant to section 654. As to counts 3 and 4—disobeying a court order—the court sentenced defendant to 256 days in jail with 128 days’ custody credit and 128 days’…