People v. R.V. (In re R.V.), S212346.
| Decision Date | 18 May 2015 |
| Docket Number | No. S212346.,S212346. |
| Citation | 187 Cal.Rptr.3d 882,349 P.3d 68,61 Cal.4th 181 |
| Court | California Supreme Court |
| Parties | In re R.V., a Person Coming Under the Juvenile Court Law. The People, Plaintiff and Respondent, v. R.V., Defendant and Appellant. |
Cindy Brines, Verdugo, under appointment by the Supreme Court, for Defendant and Appellant.
Paulino G. Durán, Public Defender (Sacramento) and Arthur L. Bowie, Assistant
Public Defender, for the Office of the Public Defender for Sacramento County as Amicus Curiae on behalf or Defendant and Appellant.
Aimee Feinberg ; Tamara Lange and Michael Harris for National Center for Youth Law as Amicus Curiae on behalf or Defendant and Appellant.
Susan L. Burrell and L. Richard Braucher, Richmond, for Youth Law Center and Pacific Juvenile Defender Center as Amicus Curiae on behalf or Defendant and Appellant.
Kamala D. Harris, Attorney General, Dane R. Gillette, Chief Assistant Attorney General, Julie L. Garland, Assistant Attorney General, Steven T. Oetting, Deputy State Solicitor General, Melissa Mandel, Charles C. Ragland, Kathryn Kirschbaum, Lise S. Jacobson and Sean M. Rodriquez, Deputy Attorneys General, for Plaintiff and Respondent.
A minor who is the subject of a wardship petition under Welfare and Institutions Code1 section 601 or 602 has, like an adult facing criminal prosecution, a due process right not to be tried while mentally incompetent. Section 709 establishes procedures for juvenile courts to follow so as to ensure that minors are not subject to adjudication while their competency is impaired.
We decide two issues in this case; first, whether under section 709 a minor is presumed competent and bears the burden of proving otherwise by a preponderance of the evidence and, second, what is the proper standard for reviewing on appeal a challenge to the sufficiency of the evidence supporting the juvenile court's determination that the minor was competent to proceed.
Section 709 is silent regarding the presumption of competency and allocation of the burden of proof, but we find that the most straightforward reading of the statute's text is that the provision contains an implied presumption of competency. This understanding of section 709 is further supported by the legislative materials surrounding that statute's enactment, which show that lawmakers intended the juvenile courts to continue to apply to minors the adult competency scheme's presumption of competency and allocation of the burden of proof to the party claiming incompetency.
We conclude furthermore that, like a challenge to the sufficiency of the evidence supporting the verdict in an adult competency proceeding, a claim of insufficient evidence to support a juvenile court's determination in a competency proceeding is reviewed deferentially under the substantial evidence test. In the present matter, the evidence before the juvenile court consisted solely of the court-appointed expert's report and testimony, and the materials on which the expert based his opinion, that 16–year–old R.V. was incompetent to stand trial. In these circumstances, we review the juvenile court's determination by asking whether the weight and character of that evidence is such that the juvenile court could not reasonably have rejected it.
Having viewed the evidence presented in the case in the light most favorable to the juvenile court's determination of competency, as we must, we nonetheless conclude that the court could not reasonably have rejected the qualified expert's compelling, well-supported, and unequivocal opinion that minor was not competent to proceed to trial.
The Court of Appeal concluded, to the contrary, that the juvenile court's reasons for declining to accept the expert's opinion were supported by substantial evidence in the record, and upheld the judgment below. Accordingly, the Court of Appeal's judgment is reversed.
On a weekday morning in March 2012, officers from the La Habra Police Department responded to a 911 call reporting that a juvenile was threatening family members with a knife. Jose Cruz, who resided with minor, minor's stepsibling, and minor's mother, told police that he had awakened minor for school around 7:00 a.m. Minor became angry and starting throwing things, saying he did not want to go to school. Cruz argued with minor, warning him that he was going to miss his bus. In response, minor clenched his fists and told Cruz, “I'm going to fuck you up,” then continued to throw and kick things around the living room. When Cruz told minor to calm down, minor held out a knife and said he would kill Cruz if he called the police. According to Cruz, minor did not move toward him with the weapon.
Minor's mother confirmed that minor had been throwing things around the living room, and told police that she saw him knock a small television set to the floor. According to minor's mother, minor moved from the living room to the bedroom and started yelling, He warned his mother, Minor's mother saw that he had a small silver knife in his hand.
Javier Naranjo, the family's landlord, also spoke with the officers. He told them that he had entered the residence after hearing the sound of something breaking and saw minor kick a DVD player in the living room. He also overheard minor arguing with Cruz and threatening to stab him with a knife.
When Naranjo likewise told minor to calm down, minor threatened to kill him as well. Naranjo then saw minor go into his bedroom and stab a bed three times.
Minor complied with the officers' order to raise his hands in the air. As minor was being handcuffed, he mentioned that the knife, a multitool with a two-inch blade, was in his front right pocket. Minor explained to one of the officers that he was upset and trying to scare his mother, and indicated that he had trouble with his parents. According to that officer's report, minor appeared to have a difficult time understanding the officer's questions and seemed confused about the incident.
All three witnesses reported to police that minor had psychological problems. His mother indicated that for the past four weeks he had not taken his medication, Abilify. Cruz explained that minor is “different every day” and “with each episode he gets worse.” Minor was taken into custody and transported to a juvenile detention facility.
Three days after the incident, the Orange County District Attorney filed a section 602 petition to declare minor a ward of the juvenile court. The petition alleged that minor committed two misdemeanor counts of brandishing a deadly weapon (Pen.Code, § 417, subd. (a)(1) ), and one misdemeanor count of vandalism (Pen.Code, § 594, subds. (a), (b)(2)(A) ). About three weeks later, defense counsel expressed a doubt regarding minor's competency to stand trial. In accordance with statutory procedures, the court determined there was substantial evidence raising a doubt as to minor's competency, suspended proceedings, and appointed a forensic psychologist, Haig J. Kojian, Ph.D., to evaluate minor. (See § 709, subd. (a).) Although the court also ordered minor released on the home supervision program pending the competency hearing, minor was returned to juvenile detention 10 days later for violating the conditions of his release.
Dr. Kojian's nine-page report concluded that minor presently was not competent to stand trial. Although defense counsel offered to submit the question of competency on the basis of Dr. Kojian's written report, the prosecutor expressed concern that Dr. Kojian had not administered any diagnostic tests to minor and requested a hearing at which Dr. Kojian could be questioned. The court granted the request.
At the hearing held one week later, Dr. Kojian explained, consistently with his written report, the basis for his conclusion that minor was not competent to stand trial. At the conclusion of the hearing, the court expressed its view that the law presumes minor is competent and places on him the burden of proving incompetency by a preponderance of the evidence. The court then ruled that minor had not met his burden of proof, found minor competent to stand trial, and ordered the reinstatement of proceedings.
Immediately after the court's competency determination, minor waived his various rights and entered a “slow plea,” submitting the matter to the court for adjudication based on the police report. The court found the allegations in the wardship petition to be true, declared minor a ward of the juvenile court, and placed him on probation.
The Court of Appeal affirmed the judgment. It first agreed with the juvenile court that a minor is presumed competent and bears the burden of proving by a preponderance of the evidence that he or she is not competent to be adjudicated under the juvenile court law. Applying a substantial evidence standard of review, the Court of Appeal upheld the juvenile court's determination that minor was competent to proceed and affirmed the judgment.
This court granted minor's petition for review.
We briefly review the law regarding competency to stand trial and some of the legal developments that preceded the enactment of section 709. This history guides our interpretation of the statute.
The constitutional right to due process of law prohibits the trial of a mentally incompetent criminal defendant. (People v. Medina (1990) 51 Cal.3d 870, 881, 274 Cal.Rptr. 849, 799 P.2d 1282 ; Drope v. Missouri (1975) 420 U.S. 162, 172–173, 95 S.Ct. 896, 43 L.Ed.2d 103.) Due process principles further require trial courts to employ procedures to guard against the trial of an incompetent defendant. (People v. Hale (1988) 44 Cal.3d 531, 539, 244 Cal.Rptr. 114, 749 P.2d 769 ; People v. Pennington (1967) 66 Cal.2d 508, 518, 58 Cal.Rptr....
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