California, United States of America
The following excerpt is from People v. Ramos, B242911 (Cal. App. 2014):
Defendant contends that the trial court's failure to hold a competency hearing requires reversal of the judgment, and the case must be remanded for retrial, assuming he is competent at the time of such trial. In anticipation of an argument by respondent that the matter should be conditionally reversed for a retrospective determination of competence if this court agrees with defendant's arguments, defendant argues that a concurrent determination is needed, citing Pate v. Robinson (1966) 383 U.S. 375, 387. Because we find the trial court did not err or abuse its discretion in finding a lack of substantial evidence of new circumstances justifying a finding of incompetence, we need not address the feasibility of a limited remand in this case for the purpose of a retrospective competency hearing. (See People v. Lightsey, supra, 54 Cal.4th at pp. 705-711.)
Defendant contends that, given that our justice system is a system largely of pleas (Missouri v. Frye (2012) ___ U.S. ___, ___ [132 S.Ct. 1399, 1407]), due process requires that the accused be competent to evaluate a proposed plea agreement. Due to his psychosis, defendant argues, he was in no position to understand the required components of a plea disposition. Under these circumstances, it was offensive to fundamental fairness that he was forced to trial and given a life sentence.
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