BILL ANALYSIS                                                                                                                                                                                                    







                      SENATE COMMITTEE ON PUBLIC SAFETY
                             Senator Mark Leno, Chair                A
                             2009-2010 Regular Session               B

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          AB 1516 (Lieu)                                             6
          As Amended June 29, 2009
          Hearing date:  July 7, 2009
          Penal Code
          MK:mc

                             CRIMINAL PROCEDURE: DISCOVERY  

                                       HISTORY

          Source:  Los Angeles District Attorney's Office

          Prior Legislation: None

          Support: Crime Victims United; California District Attorneys  
          Association 

          Opposition:California Attorneys for Criminal Justice; California  
          Public Defenders Association

          Assembly Floor Vote:  Ayes 76 - Noes 1



                                         KEY ISSUE
           
          SHOULD THE COURT BE REQUIRED TO ORDER A DEFENDANT IN A CRIMINAL  
          ACTION TO SUBMIT TO EXAMINATION BY A PROSECUTION-RETAINED MENTAL  
          HEALTH EXPERT WHENEVER A DEFENDANT PLACES HIS OR HER MENTAL STATE IN  
          ISSUE?


                                       PURPOSE




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          The purpose of this bill is to require the court to order a  
          defendant in a criminal action to submit to examination by a  
          prosecution-retained mental health expert whenever a defendant  
          places his or her mental state in issue.
          
           Existing law requires the prosecuting attorney to disclose to  
          the defendant or his or her attorney all of the following  
          materials and information, if it is in the possession of the  
          prosecuting attorney or if the prosecuting attorney knows it to  
          be in the possession of the investigating agencies:

                 The names and addresses of persons the prosecutor  
               intends to call as witnesses at trial.
                 Statements of all defendants.
                 All relevant real evidence seized or obtained as a part  
               of the investigation of the offenses charged.
                 The existence of a felony conviction of any material  
               witness whose credibility is likely to be critical to the  
               outcome of the trial.
                 Any exculpatory evidence.
                 Relevant written or recorded statements of witnesses or  
               reports of the statements of witnesses whom the prosecutor  
               intends to call at the trial, including any reports or  
               statements of experts made in conjunction with the case,  
               including the results of physical or mental examinations,  
               scientific tests, experiments, or comparisons which the  
               prosecutor intends to offer in evidence at the trial.   
               (Penal Code  1054.1(a) to (f).)
           
           Existing law  mandates the defendant and his or her attorney must  
          disclose to the prosecuting attorney:

                 The names and addresses of persons, other than the  
               defendant, he or she intends to call as witnesses at trial,  
               together with any relevant written or recorded statements  
               of those persons, or reports of the statements of those  
               persons, including any reports or statements of experts  
               made in connection with the case, and including the results  
               of physical or mental examinations, scientific tests,  




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               experiments, or comparisons which the defendant intends to  
               offer in evidence at the trial.
                 Any real evidence which the defendant intends to offer  
               in evidence at the trial.  (Penal Code  1054.3(a) to (c).)
           
           Existing law  states nothing in the codes related to discovery  
          shall be construed as limiting any law enforcement or  
          prosecuting agency from obtaining non-testimonial evidence to  
          the extent permitted by law on the effective date of this  
          provision.  (Penal Code  1054.4.)


           This bill  provides that unless otherwise specifically addressed  
          by an existing provision of law, whenever a defendant in a  
          criminal action or a minor in a juvenile proceeding brought  
          pursuant to a petition alleging the juvenile to be within  
          Section 602 of the Welfare and Institutions Code places in issue  
          his or her mental state at any phase of the criminal action or  
          juvenile proceeding through the proposed testimony of any mental  
          health expert, upon timely request by the prosecution, the court  
          shall order that the defendant or juvenile submit to examination  
          by a prosecution-retained mental health expert.


           This bill  provides that the prosecution shall bear the cost of  
          any such mental health expert's fees for examination and  
          testimony at a criminal trial or juvenile court proceeding.


           This bill  provides that the prosecuting attorney shall submit a  
          list of tests proposed to be administered by the prosecution  
          expert to the defendant in a criminal action or a minor in a  
          juvenile proceeding.  At the request of the defendant in a  
          criminal action or a minor in a juvenile proceeding, a hearing  
          shall be held to consider any objections raised to the proposed  
          tests before any test is administered.  The trial court shall  
          make a threshold determination that the proposed tests bear some  
          reasonable relation to the mental state placed in issue by the  
          defendant in a criminal action or a minor in a juvenile  
          proceeding.  For the purposes of this subdivision, the term  




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          "tests" shall include any and all assessment techniques such as  
          a clinical interview or a mental status examination.


           This bill  provides that the purpose of this subdivision is to  
          respond to Verdin v. Superior Court (2008) 43 Cal.4th 1096,  
          which held that only the Legislature may authorize a court to  
          order the appointment of a prosecution mental health expert when  
          a defendant has placed his or her mental state at issue in a  
          criminal case or juvenile proceeding pursuant to Section 602 of  
          the Welfare and Institutions Code.  Other than requiring the  
          court to order testing by prosecution-retained mental health  
          experts in response to Verdin v. Superior Court, supra, it is  
          not the intent of the Legislature to disturb, in any way, the  
          remaining body of case law governing the procedural or  
          substantive law that controls the administration of these tests  
          or the admission of the results of these tests into evidence.

                                          
                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION
          
          California continues to face a severe prison overcrowding  
          crisis.  The Department of Corrections and Rehabilitation (CDCR)  
          currently has about 170,000 inmates under its jurisdiction.  Due  
          to a lack of traditional housing space available, the department  
          houses roughly 15,000 inmates in gyms and dayrooms.   
          California's prison population has increased by 125% (an average  
          of 4% annually) over the past 20 years, growing from 76,000  
          inmates to 171,000 inmates, far outpacing the state's population  
          growth rate for the age cohort with the highest risk of  
          incarceration.<1>

          In December of 2006 plaintiffs in two federal lawsuits against  
          ---------------------------
          <1>  "Between 1987 and 2007, California's population of ages 15  
          through 44 - the age cohort with the highest risk for  
          incarceration - grew by an average of less than 1% annually,  
          which is a pace much slower than the growth in prison  
          admissions."  (2009-2010 Budget Analysis Series, Judicial and  
          Criminal Justice, Legislative Analyst's Office (January 30,  
          2009).)



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          CDCR sought a court-ordered limit on the prison population  
          pursuant to the federal Prison Litigation Reform Act.  On  
          February 9, 2009, the three-judge federal court panel issued a  
          tentative ruling that included the following conclusions with  
          respect to overcrowding:

               No party contests that California's prisons are  
               overcrowded, however measured, and whether considered  
               in comparison to prisons in other states or jails  
               within this state.  There are simply too many  
               prisoners for the existing capacity.  The Governor,  
               the principal defendant, declared a state of emergency  
               in 2006 because of the "severe overcrowding" in  
               California's prisons, which has caused "substantial  
               risk to the health and safety of the men and women who  
               work inside these prisons and the inmates housed in  
               them."  . . .  A state appellate court upheld the  
               Governor's proclamation, holding that the evidence  
               supported the existence of conditions of "extreme  
               peril to the safety of persons and property."  
               (citation omitted)  The Governor's declaration of the  
               state of emergency remains in effect to this day.

               . . .  the evidence is compelling that there is no  
               relief other than a prisoner release order that will  
               remedy the unconstitutional prison conditions.

               . . .

               Although the evidence may be less than perfectly  
               clear, it appears to the Court that in order to  
               alleviate the constitutional violations California's  
               inmate population must be reduced to at most 120% to  
               145% of design capacity, with some institutions or  
               clinical programs at or below 100%.  We caution the  
               parties, however, that these are not firm figures and  
               that the Court reserves the right - until its final  
               ruling - to determine that a higher or lower figure is  
               appropriate in general or in particular types of  
               facilities.




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               . . .

               Under the PLRA, any prisoner release order that we  
               issue will be narrowly drawn, extend no further than  
               necessary to correct the violation of constitutional  
               rights, and be the least intrusive means necessary to  
               correct the violation of those rights.  For this  
               reason, it is our present intention to adopt an order  
               requiring the State to develop a plan to reduce the  
               prison population to 120% or 145% of the prison's  
               design capacity (or somewhere in between) within a  
               period of two or three years.<2>

          The final outcome of the panel's tentative decision, as well as  
          any appeal that may be in response to the panel's final  
          decision, is unknown at the time of this writing.

           This bill  does not appear to aggravate the prison overcrowding  
          crisis outlined above.

                                      COMMENTS

          1.    Need for This Bill  

          According to the author:

              A recent California Supreme Court Case (Verdin v.  
              Superior Court) held that the prosecution is no longer  
              entitled to a court order requiring a defendant to  
              submit to a mental health examination by a prosecution  
              expert after the defendant has claimed a mental defense.
               
              The California Supreme Court in Verdin reasoned that a  
              -----------------------
          <2>  Three Judge Court Tentative Ruling, Coleman v.  
          Schwarzenegger, Plata v. Schwarzenegger, in the United States  
          District Courts for the Eastern District of California and the  
          Northern District of California United States District Court  
          composed of three judges pursuant to Section 2284, Title 28  
          United States Code (Feb. 9, 2009).



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              mandatory psychiatric examination is a form of pretrial  
              discovery that is not mentioned or authorized in Penal  
              Code  1054.5 et. seq.  The court held that California  
              case law specifically allowing such orders for mental  
              health examinations has been superseded by California  
              Penal Code 1054 et. seq. as enacted by Proposition 115.   
              The court concluded its opinion in Verdin by stating in  
              footnote 9, 'The Legislature remains free, of course, to  
              establish such a rule within constitutional limits.'   
              [The court is saying Prop 115 limited discovery and we,  
              the court, can't do anything about it, but you, the  
              legislature, can.]
               
              It is critical in criminal cases in which defendants  
              claim a mental defense that they be subject to a mental  
              health examination by a prosecution expert to  
              independently evaluate the merits of their claim.  The  
              right of the prosecution to do so has been recognized  
              for at least 35 years.  (People v. Danis (1973)  
              Cal.App.3d. 782; People v. Carpenter (1997) 15 Cal.4th  
              312; People v. McPeters (1992) 2 Cal.4th 1148.)  Even  
              before Danis, such prosecution examinations before trial  
              were routine custom and practice in criminal cases.  As  
              a result of Verdin, the prosecution cannot request a  
              pretrial mental examination by a prosecution expert over  
              a defense objection,  even after the defendant has  
              placed his mental state in issue by asserting a  
              psychiatric defense or retaining mental health experts  
              on his behalf.  This means the prosecution has no means  
              to independently investigate the appropriateness of the  
              mental defense.

          2.    Proposition 115 and Statutory History of Discovery  

          California discovery statutes underwent major changes when the  
          electorate approved Proposition 115.  "On June 5, 1990, the  
          voters of California passed Proposition 115, the Crime Victims  
          Justice Reform Act.  The initiative implemented a broad range of  
          statutory and constitutional changes relating to California's  
          criminal justice system.  For the most part, these changes limit  




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          the procedural rights of the accused and increase the rights and  
          discretion of the prosecution in an effort to harmonize the  
          system with federal law.  By creating a statutory and reciprocal  
          discovery scheme in anticipation of trial, Proposition 115  
          dramatically alters the discovery process in criminal cases and  
          may well have set a trend that other states will follow.  In  
          particular, its changes to court-ordered defense discovery  
          undermine the reliability of  preliminary hearings and plea  
          bargaining."  (Berend, Less Reliable Preliminary Hearings and  
          Plea Bargaining in Criminal Cases in California:  Discovery  
          Before and After Proposition 115, (1998) 48 Am. U. L. Rev 465,  
          466; People vs. Verdin (hereinafter Verdin) (2008) 43 Cal.4th  
          1096, 1103.)
           
          Proposition 115 explicitly states "no discovery shall occur in  
          criminal cases except as provided by this chapter, other express  
          provisions, or as mandated by the Constitution of the United  
          States."  (Penal Code  1054(e).)  Prior to the passage and  
          application of Proposition 115, the courts routinely authorized  
          access to a criminal defendant by the People's mental health  
          expert when the defendant places his or her mental state at  
          issue.  (See People vs. McPeters (1992) 2 Cal.4th 1148; People  
          vs. Carpenter (1997) 15 Cal.4th 312;  People vs. Danis (1973) 31  
          Cal.App.3rd 782.)  "Prosecutorial discovery from a criminal  
          defendant in the form of a court-ordered mental examination was  
          permissible even absent an 'authorizing statute', because the  
          trial court possessed inherent power to order such discovery."   
          (Danis at 786; Verdin at 1106.]  However, despite this  
          long-standing precedent, the California Supreme Court ruled in  
          Verdin in 2008 that the trial courts have no authority to order  
          the defendant to submit to an examination because it is not  
          explicitly authorized by Penal Code Section 1054.
           
          3.  People v. Verdin  

          Verdin involved a defendant charged with the attempted murder of  
          his wife who claimed diminished actuality at trial.  The People  
          claimed that because the defendant placed his mental state in  
          issue, it was also entitled examine the defendant.  The trial  
          court agreed but the Court of Appeals denied the request.  The  




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          California Supreme Court stayed the People's request pending a  
          formal ruling.
           
          The Court ruled, "Whether and when trial courts can order  
          persons to undergo an undesired psychiatric examination is a  
          complicated question.  This case does not require us to plumb  
          the depths of this complex issue.  Instead, we need merely to  
          interpret section 1054.  As explained above, we find the trial  
          court's order granting the prosecution access to petitioner for  
          purposes of having a prosecution expert conduct a mental  
          examination is a form of discovery that is not authorized by the  
          criminal discovery statutes or any other statute, nor is it  
          mandated by the United States Constitution.  Although we have in  
          the past found merit in a rule authorizing such discovery when a  
          defendant places his mental state in issue (McPeters, supra, 2  
          Cal.4th 1148), following Proposition 115 and the enactment of  
          the exclusivity guidelines in section 1054(e), we are no longer  
          free to create such a rule of criminal procedure, untethered to  
          a statutory or constitutional base.  Our conclusion renders it  
          unnecessary to decide whether the trial court's order violates  
          petitioner's constitutional rights.  The Legislature remains  
          free, of course, to establish such a rule within constitutional  
          limits."  (Verdin at 1116.)
           
          4.  Constitutional Issues   

          The Fifth Amendment of the U.S. Constitution provides that no  
          person shall be compelled to give evidence against him or  
          herself.  Defendants cannot be forced to testify or submit to  
          questioning of an incriminating nature.  Failure of the  
          defendant to testify at trial may not be presented to the jury  
          as evidence of his or her guilt. "The 5th Amendment commands  
          that no person shall be compelled in any criminal case to be a  
          witness against himself.  The essence of this basic  
          constitutional principle is the requirement that the state  
          proposing to convict and punish an individual must produce the  
          evidence against him by the independent labor of its officers,  
          not by the simple, cruel expedient of forcing it from his own  
          lips.  The availability of the privilege against  
          self-incrimination does not turn upon the type of proceeding in  




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          which its protection is invoked, but upon the nature of the  
          statement or admission and the exposure that it invites."   
          (Culombe vs. Connecticut (1961) 367 U.S. 568, 581.)
           
          However, under certain circumstances, the defendant's failure to  
          submit to a mental examination when he or she raises an issue of  
          mental health as a defense may be used against him or her.   
          (Buchanan vs. Kentucky (1987) 483 U.S. 402, 422; Estelle vs.  
          Smith (1981) 451 U.S. 454, 468.]  "When a defendant asserts the  
          insanity defense and introduces supporting psychiatric  
          testimony, his silence may deprive the State of the only  
          effective means it has of controverting his proof on an issue  
          that he interjected into the case.  Accordingly, several Courts  
          of Appeals have held that, under such circumstances, a defendant  
          can be required to submit to a sanity examination conducted by  
          the prosecution's psychiatrist.  A criminal defendant, who  
          neither initiates a psychiatric evaluation nor attempts to  
          introduce any psychiatric evidence, may not be compelled to  
          respond to a psychiatrist if his statements can be used against  
          him . . . . "  [Estelle at 468.]  This bill requires courts to  
          make the defendant available to the People when the defendant  
          places his or her mental state in issue.  It is unclear what  
          consequences a defendant who refuses will face, but contempt of  
          court or disclosure of non-cooperation to the jury seems likely.




















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          5.  Prosecution Access to Defendant for Mental Health Exam  

          This bill is in response to the Verdin decision and provides  
          that whenever a defendant or juvenile places his or her mental  
          state at issue, the court shall order that the defendant or  
          juvenile submit to examination by a prosecution-retained  
          witness.  The Los Angles District Attorney's Office, the sponsor  
          of this bill, argues:

              It is critical in criminal cases in which defendants  
              claim a mental defense that they be subject to a mental  
              health examination by a prosecution expert to  
              independently evaluate the merits of their claim.  The  
              right of the prosecution to do so has been recognized at  
              least 35 years.  (People v. Danis (1973) Cal. App 3d  
              782; People v. Carpenter (1997) 15 Cal 4th 312; People  
              v. McPeters (1992) 2 Cal. 4th 1148) Even before Danis,  
              such prosecution examinations before trial were routine  
              custom and practice in criminal cases.

          The recent amendments to the bill were an attempt to deal with  
          opposition concern that caselaw that existed before Verdin and  
          put parameters and limitations on when a mental exam by a  
          prosecutor, such as the mental examiner could not ask about the  
          facts of the case, were not incorporated by this bill.  The June  
          29th amendment explicitly states that it is not the intent to  
          disturb "the remaining body of case law governing procedural or  
          substantive law that controls the administration of these tests  
          or the admission of the results of these tests into evidence."

          SHOULD THE COURT BE REQUIRED TO ORDER A DEFENDANT IN A CRIMINAL  
          ACTION TO SUBMIT TO EXAMINATION BY A PROSECUTION-RETAINED MENTAL  
          HEALTH EXPERT WHENEVER A DEFENDANT PLACES HIS OR HER MENTAL  
                                                    STATE IN ISSUE?

          6.    Opposition  

          Despite the recent amendments, California Attorneys for Criminal  
          Justice (CACJ) and the California Public Defenders Association  




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          remain opposed to this bill.  Specifically, CACJ states:

              In footnote 9 of the Verdin decision the court opines  
              that the Legislature is free to amend PC 1054.3 if it so  
              wishes to allow the procedure sought in Verdin by the  
              prosecution.  However, simply amending PC 1054.3 as AB  
              1516 seeks to do will not achieve the result sought by  
              the prosecution in Verdin because of constitutional bars  
              to such a procedure.  Indeed, the Supreme Court foresaw  
              this very problem by stating that its decision was based  
              on statutory grounds alone and made it "unnecessary to  
              decide whether the trial court's order violates  
              petitioner's constitutional rights." (Verdin at p. 116)

              AB 1516 would violate the defendant's privilege against  
              self-incrimination under the Fifth Amendment to the  
              United States Constitution.  It would do so by  
              compelling the defendant to provide information to a  
              prosecution witness (the mental health expert) who would  
              then become a witness against the defendant in his  
              criminal trial or juvenile delinquency proceeding.

              CACJ would refer you to the United States Supreme Court  
              decision in Estelle v. Smith (1981) 451 U.S. 454, 101 S.  
              Ct. 1866 which held, under very similar circumstances,  
              that it was violation of the defendant's Fifth Amendment  
              privilege for the government to use as evidence against  
              the defendant the substance of his disclosures during  
              pretrial psychiatric examination.  The Estelle case is  
              discussed in Verdin.  While the Verdin court grounded  
              its decision on statutory grounds, it clearly  
              acknowledges that there are significant due process  
              issues connected to the procedure your bill seeks to  
              codify.  The opinion went on to say that this was a  
              "complicated question" and a "complex issue." (Verdin at  
              p. 116) This reinforces our point that simply amending  
              PC 1054.3 will not accomplish what AB 1516 sets out to  
              do.

          DO CONSTITUTIONAL QUESTIONS STILL EXIST WITH ALLOWING THESE  












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          EXAMS?


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