California v. Hines
Annotate this CaseDefendant-appellant Brandon Hines was convicted by jury of illegally possessing firearms while out on bond, as well as spousal abuse and witness intimidation. The trial court sentenced him to 11 years 4 months in prison. During trial proceedings, Hines acted disruptively by making delusional and paranoid comments about the prosecutor. There was also evidence Hines had suffered, and continued to suffer, from mental illness. As a result, defense counsel twice asked to have Hines evaluated psychologically. The evaluations didn’t adequately address Hines’s competence to stand trial within the meaning of Penal Code section 1368. The trial judge declined to declare a doubt about his competence and proceeded to jury selection. In the middle of trial was when defense counsel declared he had come to doubt his client's competence. A psychiatrist examined Hines and diagnosed him as having schizophrenia, bipolar disorder, anxiety, depression, and post-traumatic stress disorder. Defense counsel didn’t call the psychiatrist to testify but represented he had offered the qualified opinion that Hines wasn’t competent to stand trial. The trial judge again declined to declare a doubt as to Hines’s competence and refused to suspend the trial on the ground Hines had in fact been assisting in his defense. Hines then testified at some length without further incident, and the jury convicted him as charged. On appeal, Hines argued: (1) the trial judge was required to suspend the trial and hold a full competency hearing under Penal Code section 1368; and (2) the trial court erred in admitting certain rebuttal testimony. The Court of Appeal affirmed: since the trial judge didn’t declare a doubt about Hines’s competence, the Court felt compelled to affirm unless defense counsel presented substantial evidence to doubt Hines’s competence. "Hines’s conduct and the information defense counsel adduced about him was worrisome but didn’t constitute substantial evidence of his incompetence because defense counsel didn’t link his outbursts and mental illness to any limitation on his ability to understand the proceedings or provide rational assistance to defense counsel." Further, the trial court did not abuse its discretion in admitting the testimony, and "in any event, the admission was harmless."
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