In re Sims
Annotate this CasePetitioner Karen Sims, a former attorney diagnosed with serious mental illness, was convicted of murdering her husband Henry Sims in 2006 and sentenced to prison for a term of 50 years to life. After her conviction and sentence were affirmed on direct appeal in 2008, she petitioned for a writ of habeas corpus with the California Supreme Court in 2011, claiming her conviction was invalid because she was incompetent to stand trial. That petition was ultimately denied. In 2016, she filed another petition for habeas relief with the Supreme Court on the same grounds, but adding additional information about her postconviction mental health problems as they related to timeliness. The Court of Appeal determined that the trial court was confronted with objectively observable evidence of defendant’s bizarre legal defense, and heard her statements in open court. "Even to a casual observer, the manner in which defendant conducted her defense was not rational." Because Penal Code section 1367, subdivision (a), requires that a defendant be able to assist counsel or conduct her own defense “in a rational manner,” these additional circumstances required the appointment of counsel and/or the declaration of a doubt as to defendant’s competence. Further, the court was warned that defendant stopped taking antipsychotic medications prescribed for her, and that she would "likely become incompetent. ... If it is true that counsel attempted to communicate his concerns to the court, this would constitute evidence of changed circumstances that should have compelled the suspension of proceedings pursuant to Penal Code section 1367 et seq. to evaluate defendant’s competence." The Court granted Sims petition for habeas corpus, remanded the matter to the trial court for a hearing on petitioner's competence to stand trial.
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