People v. Padillia-Reyes CA1/5

Filed 12/11/25 P. v. Padillia-Reyes CA1/5 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FIVE

THE PEOPLE, A171317 Plaintiff and Respondent, v. (Contra Costa County Super. Ct. No. 01-24-02120) OLIVIA PADILLA-REYES, Defendant and Appellant.

Defendant Olivia Padilla-Reyes appeals the trial court’s order authorizing the Department of State Hospitals (DSH) to involuntarily administer medication pursuant to Penal Code section 1370, subdivision (a)(2)(B), after she was declared incompetent to stand trial.1 She argues that the court violated her rights to due process and equal protection by ordering her involuntarily medicated without an evidentiary hearing. As Padilla- Reyes has since been restored to competency, we dismiss this appeal as moot. We further decline to exercise our discretion to address Padilla-Reyes’s constitutional challenges because she forfeited them by failing to request an evidentiary hearing below.

1 All further statutory references are to the Penal Code unless otherwise

specified.

1

I. BACKGROUND In May 2024, a felony complaint was filed against Padilla-Reyes, charging her with arson of a structure or forest. (§ 451, subd. (c).) The following month, defense counsel expressed doubt as to Padilla-Reyes’s competence to stand trial. After conducting an in-camera hearing, the trial court agreed and suspended criminal proceedings. The court appointed two doctors to evaluate Padilla-Reyes. It further directed the doctors to address whether her “mental disorder requires medical treatment with antipsychotic medication.” Both doctors submitted written reports and concluded that Padilla- Reyes was incompetent to stand trial. The reports noted that she appeared to meet the diagnostic criteria for unspecified schizophrenia disorder. One report recommended that Padilla-Reyes be treated with antipsychotic and related medications and concluded that her “capacity to make decisions regarding psychotropic medication appears to be impaired.” The other report recommended that Padilla-Reyes be involuntarily medicated, if appropriate, “to assist her with obtaining and maintaining long-term psychiatric stability, reduction of risk factors as well as ultimately obtaining competency restoration.” In July 2024, the parties submitted on the reports and stipulated that they “may be deemed in evidence for competency purposes.” The trial court found that Padilla-Reyes was incompetent to stand trial, continued the suspension of criminal proceedings, and referred the matter to the Contra Costa Conditional Release Program for a competency restoration placement report. The court noted that one of the doctors opined that Padilla-Reyes met the criteria for involuntary medication under section 1370, subdivision (a)(2)(B), and that it would “take argument on that at commitment.”