People v. R.G. CA4/2

CourtCalifornia Court of Appeal
DecidedOctober 25, 2023
DocketE079979
StatusUnpublished

This text of People v. R.G. CA4/2 (People v. R.G. CA4/2) 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. R.G. CA4/2, (Cal. Ct. App. 2023).

Opinion

Filed 10/25/23 P. v. R.G. CA4/2

NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FOURTH APPELLATE DISTRICT

DIVISION TWO

THE PEOPLE,

Plaintiff and Respondent, E079979

v. (Super.Ct.No. FVI21000815)

R.G., OPINION

Defendant and Appellant.

APPEAL from the Superior Court of San Bernardino County. Shannon L.

Faherty, Judge. Dismissed.

Paul R. Krauss, under appointment by the Court of Appeal, for Defendant and

Appellant.

Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney

General, Charles C. Ragland, Assistant Attorney General, Melissa A. Mandel and Joseph

C. Anagnos, Deputy Attorneys General, for Plaintiff and Respondent.

1 INTRODUCTION

Defendant, R.G., appeals from an order declaring that he was mentally

incompetent to stand trial pursuant to Penal Code1 sections 1368, 1369, and 1370, and

ordering his commitment. On appeal, he claims the court erred in ordering an

“incompetent to stand trial” (IST) maximum commitment time of three years, where the

time is statutorily limited to two years, and that he should have been awarded 291 days

credit against the maximum commitment term for time served under a prior commitment.

Defendant also argues his counsel provided ineffective assistance by failing to insure the

accurate calculation of his IST commitment time.

The People argue the appeal should be dismissed for mootness because

defendant’s competency was restored after the notice of appeal was filed, at which time

defendant entered a nolo contendere plea, was sentenced to 2 years 8 months in prison,

with credit for 1472 days served. We dismiss the appeal as moot.

BACKGROUND

On April 29, 2021, defendant was charged by an amended information with two

counts of criminal threats against separate victims, pursuant to section 422, subdivision

(a). It was further alleged that defendant used a knife in the commission of the criminal

threats, in violation of section 12022, subdivision (b)(1), that he had previously been

convicted of a serious felony in violation of section 667, subdivision (a)(1) (a so-called

1 All further statutory references are to the Penal Code, unless otherwise specified.

2 nickel prior), and that he had suffered a prior conviction for a serious or violent felony

under the “Three Strikes” law, pursuant to section 1170.12, subdivisions (a) through (d).

On May 10, 2021, defense counsel expressed a doubt as to defendant’s

competence to stand trial, resulting in the appointment of a medical commission to

evaluate his condition. Following the appointment of a second doctor, on July 6, 2021,

the court found defendant was not competent, and suspended criminal proceedings. On

August 3, 2021, defendant was committed to the Department of State Hospitals (DSH)

for treatment to restore his mental competence.

On April 27, 2022, the Jail-Based Competency Treatment (JBCT) Program issued

a Certificate of Restoration to Mental Competence. On May 20, 2022, based on the report

of JBCT and the Certificate of Restoration to Mental Competence, the court found

defendant competent and reinstated criminal proceedings. On May 27, 2022, defendant

was arraigned on the amended information, and entered not guilty pleas to all counts and

denied special allegations.

On June 1, 2022, the People filed a second amended information, containing the

same counts charging the substantive crimes of criminal threats, along with the same

enhancement allegation of knife use, but added allegations under section 1170,

subdivision (h)(3).2 However, before defendant could be arraigned on this pleading,

another doubt as to his competence to stand trial was declared, proceedings were again

2 The second amended information also rearranged the allegations regarding defendant’s prior convictions, placing the enhancement allegation under section 667, subdivision (a)(1) and the strike allegations under sections 667, subdivision (b) through (i) and 1170.12, subdivisions (a) though (d), separately from the charged counts.

3 suspended, and a medical commission was appointed again. After competency

evaluations were conducted, on September 16, 2022, the court found defendant mentally

incompetent. He was again committed to DSH for treatment. At the October 11 hearing,

the court set his maximum commitment time at three years and awarded him 575 days

credit for time actually served. That same day, defendant appealed from this order.

The People requested judicial notice of postappeal proceedings and on June 16,

2023, we granted that request, deeming the exhibits provided by the People as part of the

record on appeal. Those documents reveal that on February 27, 2023, the court

considered updated reports regarding defendant’s condition and his IST treatment, as well

as a new Certificate of Restoration to Mental Competence (although there is no copy of

this document in the transcripts) and found defendant mentally competent to stand trial;

criminal proceedings were again reinstated.

On March 21, 2023, the court arraigned defendant on the second amended

information. After entering his not guilty pleas and denials, the defendant then entered a

plea of nolo contendere to count 1 and admitted the strike allegation pursuant to the

People’s agreement to dismiss count 2, the knife enhancements to both counts, and the

enhancement alleged pursuant to section 667, subdivision (a)(1) (the nickel prior).

Pursuant to the plea bargain (in which defense counsel did not join), the court dismissed

count 2 and the knife enhancements and the nickel prior enhancements. As provided by

the agreement, probation was denied, and defendant was committed to state prison for the

4 low term of 16 months, doubled to 32 months due to the strike allegations, and he was

awarded 1472 days as credit for time served.

DISCUSSION

Defendant appealed from the most recent order of commitment to DSH, arguing

the trial court erroneously set the maximum term at 3 years rather than the cap of 2 years

for such commitments, and that defendant’s commitment time should be further reduced

by the 291 days he spent in the prior commitment. Defendant also argues he was deprived

of effective assistance of counsel when his attorney informed the trial court that the

maximum commitment time was 3 years, rather than 2.

The People argue that the appeal should be dismissed for mootness because,

subsequent to the filing of the appeal, defendant’s competence was deemed restored,

criminal proceedings were reinstated, and he was convicted by guilty plea and sentenced.

In reply, defendant acknowledges the postappeal proceedings, but asserts we should

reach the merits anyway because his claims are capable of repetition but likely to evade

review. We conclude the issue is moot and dismissal is necessary.

It is a fundamental principle of appellate practice that an appeal will not be

entertained unless it presents a justiciable issue. (E.g., Costa Serena Owners Coalition v.

Costa Serena Architectural Com.

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People v. R.G. CA4/2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-rg-ca42-calctapp-2023.