California v. De La Rosa
Annotate this CaseDefendant Rudy Francisco De La Rosa appealed an order committing him to the trial competency program at Napa State Hospital. He contended insufficient evidence supported the finding that he was not competent to stand trial. He also contended that after the court decided his placement at Napa State Hospital, the trial court erred in denying him an opportunity to be heard. While defendant’s appeal was pending with the Court of Appeal, defense appellate counsel advised the Court that on April 2, 2013, the trial court terminated defendant’s commitment, finding that defendant had been restored to competency, and reinstated criminal proceedings. Defendant then entered a plea and the court granted probation. The State argued the issues on appeal were rendered moot due to defendant’s restoration to competency and the resumption of criminal proceedings during which defendant entered a plea and was granted probation. Defendant disagreed the issues were moot, arguing that State ignored post-"Lindsey" cases discussing the continuing stigma of a wrongful commitment. The Court of Appeal found that the issues on appeal were not moot, and that sufficient evidence supported the trial court's order finding defendant incompetent to stand trial.
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