People v. McCray
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The court case in question involves James McCray, a violent offender with mental health disorders (OMHD), who has been committed to the State Department of State Hospitals (DSH) since 2005. McCray appealed a 2022 order recommitting him for another one-year term, arguing that there was insufficient evidence to prove he represented a substantial danger to others due to his severe mental health disorder, that he voluntarily absented himself from his recommitment trial, and that the trial court did not obtain a knowing and intelligent waiver of his right to a jury from him before the trial.
The Court of Appeal of the State of California First Appellate District Division Four dismissed McCray's appeal as moot since the recommitment order he appealed from had expired and he had been recommitted for another year. However, the court addressed his claim that the trial court failed to ensure he knowingly and intelligently waived his right to a jury trial, given its recurring importance.
Upon review, the court found that the trial court relied entirely on McCray's counsel's brief questioning about his understanding of the right to a jury trial and did not take any steps to ensure McCray fully understood the significance of a jury trial and the difference between a bench trial and a jury trial. The court concluded that McCray did not make a knowing and intelligent waiver of his right to a jury trial, and highlighted the importance of the court directly informing an OMHD defendant about the right being waived to ensure a meaningful record of the defendant's understanding of a jury waiver.
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