BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                  AB 1516|
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                                 THIRD READING


          Bill No:  AB 1516
          Author:   Lieu (D)
          Amended:  7/16/09 in Senate
          Vote:     27

           
           SENATE PUBLIC SAFETY COMMITTEE  :  7-0, 7/7/09
          AYES:  Leno, Benoit, Cedillo, Hancock, Huff, Steinberg,  
            Wright

           ASSEMBLY FLOOR  :  76-1, 5/26/09 - See last page for vote


           SUBJECT  :    Criminal procedure:  discovery

           SOURCE  :     Los Angeles District Attorneys Office


           DIGEST  :    This bill authorizes 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/her mental state in issue.

           ANALYSIS  :    Existing law requires the prosecuting attorney  
          to disclose to the defendant or his/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:

          1. The names and addresses of persons the prosecutor  
             intends to call as witnesses at trial.

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          2. Statements of all defendants.

          3. All relevant real evidence seized or obtained as a part  
             of the investigation of the offenses charged.

          4. The existence of a felony conviction of any material  
             witness whose credibility is likely to be critical to  
             the outcome of the trial.

          5. Any exculpatory evidence.

          6. 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 Section 1054.1(a) to  
             (f).)
           
          Existing law mandates the defendant and his/her attorney  
          must disclose to the prosecuting attorney:

          1. The names and addresses of persons, other than the  
             defendant, he/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, experiments, or  
             comparisons which the defendant intends to offer in  
             evidence at the trial.

          2. Any real evidence which the defendant intends to offer  
             in evidence at the trial.  (Penal Code Section 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 Section  







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          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/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 may 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.  Before ordering that the defendant submit to  
          the examination, the trial court must 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  
          "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/her mental  
          state at issue in a criminal case or juvenile proceeding  
          pursuant to Section 602 of the Welfare and Institutions  
          Code.  Other than authorizing the court to order testing by  
          prosecution-retained mental health experts in response to  







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           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.

           Background
           
           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 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.)

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No    
          Local:  No

           SUPPORT  :   (Verified  7/15/09)







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          Los Angeles District Attorney's Office (source)
          Crime Victims Untied
          California District Attorneys Association

           OPPOSITION  :    (Verified  7/15/09)

          California Attorneys for Criminal Justice
          California Public Defenders Association

           ARGUMENTS IN SUPPORT  :    According to the author's office:

            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  
            mandatory psychiatric examination is a form of pretrial  
            discovery that is not mentioned or authorized in Penal  
            Code Section 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  







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            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.


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







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             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.

           ASSEMBLY FLOOR  : 
          AYES:  Adams, Ammiano, Anderson, Arambula, Bill Berryhill,  
            Tom Berryhill, Blakeslee, Block, Blumenfield, Brownley,  
            Buchanan, Caballero, Charles Calderon, Carter, Chesbro,  
            Conway, Cook, Coto, Davis, De La Torre, De Leon, DeVore,  
            Emmerson, Eng, Evans, Feuer, Fletcher, Fong, Fuentes,  
            Fuller, Furutani, Gaines, Galgiani, Garrick, Gilmore,  
            Hagman, Hall, Harkey, Hayashi, Hernandez, Hill, Huber,  
            Huffman, Jeffries, Jones, Knight, Krekorian, Lieu, Logue,  
            Bonnie Lowenthal, Ma, Mendoza, Miller, Monning, Nava,  
            Nestande, Niello, Nielsen, John A. Perez, V. Manuel  
            Perez, Portantino, Price, Ruskin, Salas, Saldana, Silva,  
            Smyth, Solorio, Audra Strickland, Swanson, Torlakson,  
            Torres, Torrico, Tran, Villines, Yamada
          NOES:  Skinner
          NO VOTE RECORDED:  Beall, Duvall, Bass


          RJG:do  7/16/09   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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