Ramirez v. Super. Ct.
Annotate this CaseGuadalupe Ramirez petitioned for mandamus relief, asking the Court of Appeal to direct the superior court to vacate its order extraditing him to Arizona. Ramirez contended he was mentally incompetent and the court's order extraditing him violated his due process rights. Ramirez sought placement in an appropriate mental health facility, as described by California's criminal competency statutes, until he could be restored to competency. In 2006, Ramirez pleaded guilty in Arizona state court to three felony sex offenses involving minors. The Arizona court sentenced him to 10 years in prison, to be followed by lifetime probation. Following his release from prison, Ramirez applied to transfer his probation to California under the Interstate Compact for Adult Offender Supervision (ICAOS). As part of his application, Ramirez waived extradition and agreed to return to Arizona if directed. After several months, during which Ramirez apparently lived in California, the Arizona court received information that Ramirez had violated the terms of his probation. Finding probable cause to believe Ramirez had violated the terms of his probation, Arizona issued a warrant for his arrest. The court appointed counsel, and Ramirez denied the allegations, with defense counsel expressing doubt about Ramirez's mental competency. Two mental health evaluators had seen Ramirez and submitted reports; both diagnosed Ramirez with schizophrenia. After hearing the evidence, the trial court found that Ramirez was not competent, either under California's criminal competency statutes or in the specific context of extradition proceedings involving identity. But the court found that Ramirez's competence was "irrelevant" given the "overwhelming" evidence of identity. The court believed there would be nothing Ramirez could do, even if he were competent, to rebut the evidence of identity. After review, the Court of Appeal agreed the superior court's extradition order had to be vacated, but for different reasons than those initially asserted by Ramirez. Finding that the trial court proceedings did not comply with ICAOS rules governing probable cause hearings, the Court of Appeal found the trial court erred by ordering Ramirez's extradition.
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