Reported / Citable
Background
A jury convicted Lidio Valdez Maldonado of continually sexually abusing his daughter. Before trial, his bizarre statements and asserted delusions led the criminal court to suspend proceedings and transfer the competency question to Los Angeles County’s specialized mental-health court. Counsel appeared at the competency hearing, but Maldonado remained at the state hospital and did not attend.
The mental-health court relied on expert reports and found Maldonado competent. Proceedings resumed, and defense counsel later declined to renew a competency objection after further conversations with him. On appeal, Maldonado argued that the federal and state constitutions gave him a right to attend the competency hearing and that his absence required reversal.
The Court’s Holding
The Second District affirmed the conviction. A criminal defendant has a due-process right to be present at a proceeding when presence bears a reasonably substantial relationship to the opportunity to defend. Assuming the competency hearing fell within that protection, any error was harmless beyond a reasonable doubt because Maldonado’s attendance would not have increased the hearing’s fairness or reliability.
The hearing turned on professional evaluations and counsel’s assessment, not testimony from Maldonado. His unusual beliefs and manner had already been observed and documented, and nothing suggested he could have supplied useful information overlooked by the evaluators. The majority therefore did not decide whether California courts may routinely conduct such hearings without the defendant. Acting Presiding Justice Wiley separately wrote that there was no constitutional error at all and emphasized counsel’s practical reasons for proceeding without disturbing a hospitalized client’s treatment.
Key Takeaways
- A defendant’s right to attend depends on whether presence could meaningfully improve the proceeding’s fairness.
- Competency hearings remain distinct from trials because expert evaluation and counsel’s observations may carry the central evidentiary weight.
- An appellate claim needs a concrete explanation of what the defendant could have contributed.
- The court left the broader categorical right unresolved, deciding the case on harmlessness.
Why It Matters
Criminal practitioners should make an express record about attendance at competency proceedings. Defense counsel who seeks the client’s presence should identify how participation could affect the evidence; counsel proceeding without the client should document informed tactical and treatment considerations. Prosecutors and courts should not read the ruling as blanket approval of absence, because the majority deliberately assumed error and relied on this record.