California v. Doron
Annotate this CaseDefendant-appellant Karl Doron appealed after his guilty plea to nine counts of robbery, two counts of attempted robbery, and allegations he was armed with a firearm during the commission of the robberies. Before entering into his plea, Doron unsuccessfully requested pretrial mental health diversion under Penal Code section 1001.36. The court sentenced Doron to a prison sentence of 10 years four months in accordance with his plea. In his initial appellate briefing, Doron contended the trial court abused its discretion by ruling he had not made a prima facie showing he was entitled to mental health diversion. After the State filed its respondent’s brief, the Legislature amended section 1001.36 to revise the eligibility test for pretrial diversion (Stats. 2022, ch. 735, § 1, eff. Jan. 1, 2023), and the parties submitted supplemental briefing on the issue. Doron then contended under the amended statute, which applied retroactively to his case, the trial court was required to find his mental disorder was a substantial factor in the commission of his crimes absent clear and convincing evidence to the contrary. He maintained there was no substantial evidence to rebut this presumption, and thus he was both eligible and suitable for pretrial mental health diversion. Doron alternatively asked the Court of Appeal remand his matter for an evidentiary hearing governed by section 1001.36’s new principles. The State conceded, and the Court of Appeal agreed, that amended section 1001.36 applied retroactively to Doron’s nonfinal judgment. The State argued, however, the proper remedy was not for the Court to engage in factfinding so as to decide whether Doron met the criteria for diversion, but to remand the matter for a new prima facie evidentiary hearing consistent with section 1001.36’s amendments. To this the Court concurred, and remanded the case with directions that the trial court consider Doron’s request for mental health diversion under amended section 1001.36.
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