People v. Adam CA4/1

California Court of Appeal Mar 26, 2024 No. D082400Unpublished

AI Brief

AI-generated · verify before citing

Holding. The court affirmed an order authorizing the involuntary administration of antipsychotic medication to a defendant found incompetent to stand trial, concluding that substantial evidence supported the findings and that any error on the commitment form was harmless.

Issues

Whether substantial evidence supports the trial court's finding that the defendant's mental disorder requires antipsychotic medication and that failure to treat it would likely result in serious harm.
Whether the trial court applied the correct legal standard regarding the probability of serious harm despite a clerical error on the commitment form.
Whether trial counsel provided ineffective assistance by failing to object to the involuntary medication order.

Disposition. Affirmed

Quotations verified verbatim against the opinion

“We conclude there is substantial evidence of each of the two elements disputed by Adam.”

“Because the trial court relied on Dr. Takamura’s recommendation in making its order, and Dr. Takamura’s opinion was that serious harm was probable rather than merely possible, “the form order’s error was harmless beyond a reasonable doubt.””

“Adam “has not established a reasonable probability that a different result would have occurred if [his] trial counsel had objected.””

Filed 3/26/24 P. v. Adam CA4/1 NOT TO BE PUBLISHED IN OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D082400

Plaintiff and Respondent,

v. (Super. Ct. Nos. MH119725, GRANT PARKER ADAM, CD296614)

Defendant and Appellant.

APPEAL from an order of the Superior Court of San Diego County, Steven E. Stone, Judge. Affirmed.

Paul R. Kraus, under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Charles C. Ragland, Assistant Attorney General, Collette C. Cavalier, and James Spradley, Deputy Attorneys General, for Plaintiff and Respondent.

After being found incompetent to stand trial and committed to a state

hospital under Penal Code1 section 1368, Grant Parker Adam appeals from a portion of the commitment order authorizing involuntary administration of antipsychotic medications. Following our own recent decision rejecting many of the same claims of error in People v. Garcia (2024) 99 Cal.App.5th 1048 (Garcia), we find no error and affirm the order. FACTUAL AND PROCEDURAL BACKGROUND Adam was charged in a complaint filed in October 2022. As amended in February 2023, the complaint charged him with making a criminal threat (§ 422; count one) while personally using a deadly or dangerous weapon, a knife (§ 12022, subd. (b)(1)); assault with a deadly weapon (§ 245, subd. (a)(1); count two); five counts of violating a protective order (§ 166, subd. (c)(1); counts three through seven); vandalism under $400 (§ 594, subd. (a)(b)(2)(A); count eight); three counts of attempted carjacking (§§ 664, 215, subd. (a); counts nine through eleven); resisting an executive officer (§ 69; count 12); assault by means of force likely to produce great bodily injury (§ 245, subd. (a)(4); count 13); and battery with serious bodily injury (§ 243, subd. (d); count 14). Adam pled not guilty to all charges. In January 2023, the trial court declared a doubt as to his competency to stand trial under section 1368. The court suspended the proceedings and directed the performance of a mental health evaluation. Dr. Benedetto Brunetto, a psychologist with the County of San Diego’s Forensic Psychiatry Clinic, evaluated Adam on February 28, 2023 and filed two reports with the court. In the first report, Dr. Brunetto

People v. Adam CA4/1

AI Brief

COURT OF APPEAL, FOURTH APPELLATE DISTRICT

DIVISION ONE

STATE OF CALIFORNIA

THE PEOPLE, D082400

More from California Court of Appeal

Related research

BUCHANAN, J.

CASTILLO, J.

AI Brief