People v. Hall
Annotate this CaseIn the State of California, a criminal defendant diagnosed with a mental disorder can be placed on mental health diversion under Penal Code section 1001.36. The provision allows such defendants to receive treatment for their mental illness and potentially avoid prosecution. However, the court may reinstate charges if the defendant's behavior while on diversion renders them unsuitable for the program. This case involved a defendant, Jasmen Lavar Hall, who was charged with carjacking and related offenses. After being placed on mental health diversion, Hall was expelled from his residential treatment program for threatening and assaulting other patients and destroying property. Following this behavior, Hall went missing for approximately six months before being apprehended. The trial court subsequently terminated Hall's diversion and reinstated the criminal proceedings. After a jury trial, Hall was convicted of the carjacking-related offenses and sentenced to an aggregate sentence of seven years eight months in prison. Hall argued that the court erred in reinstating the criminal proceedings because his actions did not meet the statutory criteria for having his diversion terminated. The Court of Appeal of the State of California Second Appellate District Division One disagreed, ruling that Hall's violent conduct and failure to comply with his treatment obligations rendered him unsuitable for diversion under Penal Code section 1001.36, subdivision (g)(3). The court therefore held that the trial court did not err in terminating Hall's diversion and reinstating the criminal proceedings, and it affirmed the judgment of conviction.
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