California v. Edwards, et al.
Annotate this CaseIn three separate cases consolidated for appeal, a trial court found defendants incompetent to stand trial and ordered them be committed to the California Department of State Hospitals (DSH) for competency treatment. When DSH failed to admit the defendants in a timely manner, the trial court issued orders to show cause why sanctions should not be imposed, and it directed DSH to admit each defendant by a particular deadline. When the defendants were not admitted by that deadline, the trial court issued sanctions of $1,000 for each day past the deadline that the defendants were not admitted, for a total of $91,000. Although only one of the sanctions orders stated sanctions were imposed pursuant to Code of Civil Procedure section 177.5, the parties proceeded on the assumption that sanctions were imposed pursuant to that section in all three cases. DSH all three sanctions orders, arguing: (1) the trial court erred in concluding DSH lacked good cause or substantial justification for failing to admit defendants by the court-ordered deadline; (2) the written orders imposing sanctions fail to specify the conduct or circumstances justifying the order in sufficient detail; and (3) the amount of sanctions imposed in each case exceeds the $1,500 limit provided in section 177.5. The Court of Appeal interpreted section 177.5 as allowing sanctions of up to $1,500 for each separate violation of a court order. The Court reversed judgment and remanded for the trial court to determine in the first instance whether DSH committed separate acts of violating a court order on each day that it failed to admit the defendants past the court-ordered deadline, or whether its failure to admit the defendants could only be considered one act of violating a court order. "If the trial court determines DSH committed separate acts of violating a court order, its written order imposing sanctions 'shall be in writing and shall recite in detail the conduct or circumstances justifying' that determination."
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