A contentious legal battle has emerged over the maximum allowable commitment period for defendants deemed incompetent to stand trial, raising questions about due process and judicial discretion. Mario Rodriguez filed a complaint with the Court of Appeal of the State of California, Sixth Appellate District, on July 10, 2024, against the Superior Court of Santa Clara County.
The case centers around whether delays caused by defense requests or external factors like the COVID-19 pandemic should toll the two-year limit set by Penal Code section 1370(c)(1) for committing an incompetent defendant. The California Supreme Court had previously ruled that the interval between filing a certificate of restoration and the court's ruling on it is included in this two-year period. However, they left open whether Rodriguez's maximum commitment time had been exceeded and what remedy might be appropriate if it had.
Rodriguez was first committed to the State Department of State Hospitals in May 2018 after being found incompetent to stand trial for several felonies. His initial commitment lasted 119 days until he was deemed competent again in September 2018. However, he was found incompetent once more in May 2019 and recommitted. By January 2020, Rodriguez was certified as restored to competency but requested a formal hearing to contest this certification. Multiple continuances were requested by his defense counsel for various reasons, including preparation time and delays caused by the COVID-19 pandemic.
The trial court faced significant challenges due to pandemic-related restrictions and backlog, leading to further delays in holding Rodriguez's restoration hearing. The defense argued that these delays should not count towards the two-year limit, while the prosecution contended that statutory rules allow for tolling based on good cause continuances.
Ultimately, the appellate court decided that section 1370(c)(1)'s two-year limit could indeed be tolled for delays attributable to defense requests or other justifiable reasons like public health emergencies. They concluded that only 664 days of Rodriguez's commitment period had elapsed when accounting for such tolling, leaving him with 66 days remaining within the statutory limit.
Rodriguez’s legal team sought dismissal of charges under Penal Code section 1385 due to exceeding the two-year limit without proper tolling considerations. However, this request was denied based on equitable principles allowing for pauses in counting days due to legitimate delays.
The case highlights complex intersections between legal statutes designed to protect defendants' rights and practical challenges courts face in ensuring timely justice. The ruling underscores judicial discretion in managing procedural timelines while balancing defendants' rights against broader public interests.
Attorneys involved include Brian C. McComas representing Mario Rodriguez and Deputy District Attorney Alexandra W. Gadeberg representing The People. The presiding judge at trial was Honorable Eric S. Geffon with Case ID H049016.