People v. Rodas
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The Supreme Court reversed the judgment of the Court of Appeal and remanded with directions to reverse Defendant’s judgment of conviction, holding that the trial court erred in failing to suspend the criminal trial and initiate competency proceedings when defense counsel declared a doubt about her client’s competence.
Here, Defendant, a formerly incompetent defendant, was restored to competence primarily through administration of medication. At the start of Defendant’s jury trial, Defendant began exhibiting signs of incompetence, and the trial court learned that Defendant had stopped taking his medication. After counsel declared a doubt as to Defendant’s competence the trial court conducted a brief colloquy with Defendant. The court then ruled that the trial could proceed. Defendant was ultimately convicted on several counts and sentenced to multiple life terms. The Supreme Court reversed, holding that the trial court’s failure to suspend proceedings and conduct a formal investigation into Defendant’s incompetence violated Defendant’s constitutional guarantee of due process.
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