People v. Mancilla CA1/3

CourtCalifornia Court of Appeal
DecidedApril 10, 2026
DocketA173911
StatusUnpublished

This text of People v. Mancilla CA1/3 (People v. Mancilla CA1/3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Mancilla CA1/3, (Cal. Ct. App. 2026).

Opinion

Filed 4/10/26 P. v. Mancilla CA1/3 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE, Plaintiff and Respondent, A173911 v. JONATHAN MANCILLA, (City & County of San Francisco Super. Ct. Nos. 23009526, Defendant and Appellant. 24022969)

During the pendency of two criminal cases involving appellant Jonathan Mancilla, the trial court found him incompetent to stand trial and committed him to the State Department of State Hospitals (DSH) under Penal Code1 section 1370. An administrative law judge (ALJ) issued an involuntary medication order (IMO) for 21 days to compel administration of antipsychotic medication to Mancilla, which has since expired. The trial court then held a separate hearing and issued a one-year IMO through August 2026. Mancilla asserts the trial court denied him a proper Marsden hearing (People v. Marsden (1970) 2 Cal.3d 118 (Marsden)) prior to his commitment. He also challenges both the 21-day IMO and the one-year IMO, and raises

1 All further statutory references are to the Penal Code.

1 claims of ineffective assistance of counsel. We dismiss Mancilla’s challenge to the 21-day IMO as moot and otherwise affirm. FACTUAL AND PROCEDURAL BACKGROUND Underlying Criminal Proceedings In September 2024, Mancilla pled guilty in case No. 23009526 to possession of a handgun by a felon (§ 29800, subd. (a)(1)). In December 2024, substitute conflict counsel Ean Vizzi was appointed to represent Mancilla in this case ahead of an anticipated sentencing hearing. Unless otherwise noted, all further dates refer to 2025. In January, Mancilla was charged by information in case No. 24022969 with making criminal threats (§ 422, subd. (a)) and assault with a deadly weapon (§ 245, subd. (a)(1)). Vizzi was also appointed to represent Mancilla in that case. In February, Mancilla filed a Marsden motion to remove Vizzi as counsel. The trial court held a Marsden hearing and denied the motion. Mental Competency Ruling In March, Vizzi expressed doubt as to Mancilla’s competency and proceedings were immediately suspended in both cases. The trial court ordered a psychologist to evaluate Mancilla’s competency to stand trial. In an April report, the psychologist opined Mancilla was not competent to proceed to trial. In May, the trial court found Mancilla was not competent to stand trial. On May 29, the court ordered Mancilla committed to DSH for up to two years, but did not enter a medication order. IMO Proceedings Mancilla was admitted to DSH on June 17.

2 On June 29, DSH petitioned the Office of Administrative Hearings for authorization to involuntarily administer antipsychotic medication to Mancilla pursuant to section 1370, subdivision (a)(2)(C), based on the certification of Dr. Sarah Polfliet. Polfliet diagnosed Mancilla with “[u]nspecified schizophrenia spectrum and other psychotic disorder” and opined antipsychotic medication was the medically necessary and appropriate treatment for Mancilla’s diagnosis. She stated Mancilla lacked capacity to make decisions as to the medication, it was probable that serious harm to his physical or mental health would result from a lack of medication, and Mancilla was a danger to others. In reaching that conclusion, Polfliet considered instances in which Mancilla expressed hearing voices, had delusions that nurses and others were persecuting him, and exhibited violent behavior after being admitted to DSH. In one such instance, on June 25, Mancilla was placed in restraints after he shouted at and argued with hospital staff, threatened to assault them, punched a window and kicked a door at the nurse’s station, and attempted to hit staff. On July 2, an ALJ held a hearing on the temporary IMO petition, at which Mancilla appeared and was represented by counsel Michele Shaddow. Vizzi was not present and the record does not reveal how Shaddow came to represent Mancilla at the July 2 hearing. After taking testimony, the ALJ issued a 21-day IMO, from June 29 to July 20. The parties stipulated to continue the ALJ’s IMO through August 3. On August 1, after holding a hearing at which Mancilla was represented by Vizzi, the court issued a one-year IMO. The court found Mancilla lacked the capacity to make decisions regarding antipsychotic medication and that serious harm to his physical or mental health was probable without treatment.

3 Mancilla appealed the ALJ’s 21-day IMO while it was still in effect; this court later deemed the notice of appeal to include the court’s one-year IMO. DISCUSSION Mancilla challenges the Marsden hearing, the 21-day IMO, and the one-year IMO. In the alternative, he argues Vizzi rendered ineffective assistance. I. The Marsden Inquiry Was Adequate Mancilla avers he was denied a proper Marsden hearing as the court failed to make an adequate inquiry. “When a defendant seeks new counsel on the basis that his appointed counsel is providing inadequate representation[,] . . . the trial court must permit the defendant to explain the basis of his contention and to relate specific instances of inadequate performance. A defendant is entitled to relief if the record clearly shows that the appointed counsel is not providing adequate representation or that defendant and counsel have become embroiled in such an irreconcilable conflict that ineffective representation is likely to result.” (People v. Smith (2003) 30 Cal.4th 581, 604.) If the trial court provides a defendant a “ ‘full opportunity to air all of his complaints, and counsel to respond to them,’ ” no more is required. (People v. Wright (2021) 12 Cal.5th 419, 441 (Wright).) We review the court’s decision not to discharge appointed counsel for abuse of discretion (Wright, supra, 12 Cal.5th at p. 440) and conclude there was none. A. Additional Background On February 21, Mancilla asked the trial court to replace Vizzi as counsel, and the court held a Marsden hearing. The court asked Mancilla

4 what he thought Vizzi was failing to do that Mancilla believed he should be doing as counsel, and Mancilla responded as follows. Mancilla claimed Vizzi was being paid by a third party to represent him and make him look guilty when “there was no case”; Vizzi was “manipulating the system” and there was a “pedophile undercover that works in the system”; Vizzi “slapped [Mancilla] in the face telling [him he] had no court date”; Vizzi was going to represent him “no matter what”; Vizzi told Mancilla he had no choice but to have Vizzi represent him because Mancilla fired a previous lawyer; Mancilla “fired” Vizzi four times before the Marsden hearing; Vizzi went to Mancilla’s door the day prior and asked if Mancilla wanted to talk; Mancilla did not like how Vizzi represented him; Vizzi was going to cause him to stay in custody longer, apparently by asking Mancilla to have a mental health evaluation, which was “inconsiderate”; Vizzi did not give Mancilla paperwork showing his official diagnosis; and Mancilla was unable to obtain video evidence of the underlying criminal conduct despite trying to do so. Vizzi declined the court’s invitation to respond. The court denied the motion, stating: “[T]o the extent there are any conflicts, I’m not sure there is, I don’t find there is anything that Mr. Vizzi has not done or should be doing differently. I find that he has properly been representing you and will continue to do so. He’s a very experienced attorney. [¶] . . . [¶] He is protecting [your rights].” B.

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Bluebook (online)
People v. Mancilla CA1/3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-mancilla-ca13-calctapp-2026.