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Date: 10-25-2024
Case Style:
The People of the State of California v. David Anthony Dean
Case Number: SWF1500705
Judge: Jeffrey J. Prvost
Court: Superior Court, Riverside County, California
Plaintiff's Attorney: Riverside County, California District Attorney's Office
Defendant's Attorney:
Description:
Riverside, California criminal defense lawyer represented the defendant charged with burglary and assault with a deadly weapon.
In 2015, David Anthony Dean broke into his parents' home and assaulted his father and half-brother with a metal rod. Dean was charged with one count of burglary and two counts of assault with a deadly weapon. Dean pleaded not guilty by reason of insanity (NGI) and, after the guilt phase of his trial, the jury found him guilty of all three counts. In the second phase of trial, the jury rejected Dean's insanity defense. The trial court, however, granted Dean a new sanity trial after finding the jury failed to give proper weight to the testimony of two court-appointed psychologists who opined Dean was not sane when he committed the crimes.
The district attorney who prosecuted the case then unsuccessfully appealed the trial court's ruling. This court found the trial court's decision was supported by ample evidence and conditionally affirmed the new trial order, directing the trial court to consider whether Dean was eligible for mental health diversion in light of recently enacted legislation providing for such relief. Shortly after remand, Dean was found incompetent to stand trial and committed to the Department of State Hospitals (DSH) for a period of around three months. After his competency was restored, Dean filed a motion to represent himself under Faretta v. California (1975) 422 U.S. 806 (Faretta), which the court granted. Dean then continued a campaign, which he began after this court's prior remand, of ex parte court filings asserting he had been wrongly convicted and that he was the victim of a wide-ranging conspiracy. Seven months later, unsurprisingly, the court declared a doubt as to Dean's competency and he was committed to the DSH a second time.
Three months after Dean was found to have regained his competency, on January 6, 2022, he again successfully moved under Faretta to represent himself. Thereafter, Dean withdrew his NGI plea. After mental health
diversion was denied, Dean continued to argue he was wrongly convicted. Dean's filings and appearances before the court during the year-long period after his Faretta motion was granted clearly evidenced his competency remained in question, but no doubt was declared. In January 2023, the trial court sentenced Dean to 19 years in state prison.
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People v. Dean, D081767 (Cal. App. Oct 25, 2024)
Outcome: We reverse the judgment of conviction. On remand, if Dean is presently competent, the trial court is directed to consider Dean's eligibility for mental health diversion in accordance with section 1001.36 and, if necessary, proceed to the sanity phase of trial. If after remand a doubt is declared as to Dean's competency, any expert appointed to evaluate Dean should specifically consider his competency to stand trial and to represent himself, and also whether Dean can maintain his competency while not in the care of the DSH.
Plaintiff's Experts:
Defendant's Experts:
Comments: