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Keywords

attorneyappealtrialdue processsustainedbench trialjury trial
appealtrialwillbaildue processjury trial

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People v. Barrett, 54 Cal.4th 1081, 281 P.3d 753, 144 Cal.Rptr.3d 661, 12 Cal. Daily Op. Serv. 8538, 2012 Daily Journal D.A.R. 10,345

Facts

Christine Barrett, diagnosed with mental retardation and other mental disorders, was civilly committed due to increasingly violent behavior. The district attorney filed a petition for her commitment under section 6500, asserting she was a danger to herself and others. Following a nonjury trial, the court found the allegations sustained and ordered her committed for one year to the State Department of Developmental Services. Barrett appealed, claiming she was denied due process and equal protection due to the lack of a jury trial.

Christine Barrett is an adult who has long been diagnosed with mental retardation and other mental disorders, and who has lived in the community while being supported and supervised by others. Because of her increasingly violent behavior, Barrett became the subject of this proceeding to civilly commit her as a 'mentally retarded person' who is a 'danger' to herself or others.

Issue

Whether Barrett was denied due process and equal protection of the law by not being advised of her right to a jury trial or having a valid waiver of that right before a bench trial.

We now decide whether the Court of Appeal properly rejected Barrett's claims that she was denied due process and equal protection of the law insofar as the record does not reveal the circumstances under which she was tried by the court, rather than by a jury.

Rule

The court determined that the statutory scheme does not expressly provide for a right to jury trial in section 6500 proceedings, and that counsel's waiver of a jury trial is sufficient to meet due process requirements.

The statutory scheme does not expressly provide either for a right to jury trial or for any related requirement that an alleged mentally retarded person be advised of, or allowed to personally act upon, any such right.

Analysis

The court analyzed the statutory framework and concluded that the nature of section 6500 proceedings, which involve individuals with cognitive impairments, justifies allowing counsel to make the tactical decision regarding a jury trial. The court found that requiring personal advisement and waiver would not serve a useful purpose and would not undermine the fairness of the proceedings.

Accordingly, consistent with closely related decisions of this court, and given the mental competence issues addressed in section 6500 proceedings as compared to other commitment scenarios, we conclude it is counsel who must make the tactical decision whether to seek or waive a jury.

Conclusion

The Supreme Court affirmed the judgment of the lower court, holding that Barrett's commitment was valid and that her due process and equal protection claims were without merit.

We therefore will affirm the judgment.

Who won?

The People (the state) prevailed in the case, as the court upheld the commitment order, finding that the statutory procedures were sufficient and that Barrett's rights were adequately protected.

The court observed that except for Alvas, supra, 221 Cal.App.3d 1459, 271 Cal.Rptr. 131, and Bailie, supra, 144 Cal.App.4th 841, 50 Cal.Rptr.3d 761, California courts have never placed any procedural conditions on the manner in which the defense demands or declines a jury under section 6500.

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