Moore v. Superior Court

Summary

The California Supreme Court held that due process does not prohibit trying or civilly committing an alleged sexually violent predator while mentally incompetent. The court distinguished the constitutional competency right applicable to criminal defendants and concluded that recognizing such a right in sexually violent predator proceedings could undermine the purposes of the Sexually Violent Predators Act. The court reversed the Court of Appeal's directive requiring a competency hearing.

Holdings

1. Due process does not require mental competence on the part of a person undergoing a commitment or recommitment trial under the SVPA; an alleged SVP may be tried, confined, and treated under the Act while mentally incompetent.
2. People v. Allen does not establish a constitutional right to competency before an SVP trial because the right to testify recognized in Allen involved a materially different claim by a presumably competent defendant and did not address whether incompetence may bar the entire proceeding.
3. The court declined to create or import criminal competency procedures into SVP proceedings because the SVPA contains no such procedures and applying the criminal scheme would create substantial uncertainty concerning placement, treatment, restoration, and public safety.

Questions Presented

1. Whether due process requires a defendant in a sexually violent predator commitment or recommitment proceeding to be mentally competent before being tried and civilly committed.
2. Whether the due process balancing analysis recognized in People v. Allen requires a competency hearing and stay of SVP proceedings when the defendant allegedly cannot understand the proceedings or assist counsel.
3. Whether the Court of Appeal properly exercised inherent authority to create competency procedures under Penal Code section 1367 et seq. for SVP proceedings.

Disposition

reversed