Unreported / Non-Citable
Background
A jury convicted Roeling Adams of four counts of second degree robbery and found true firearm-use allegations. The amended complaint also alleged two prior strike convictions. Adams represented himself at the preliminary hearing, cross-examining witnesses and challenging surveillance-video identification. The appellate opinion did not detail the robbery evidence because the appeal concerned competency and sentencing, but noted that victims identified Adams and surveillance corroborated their testimony.
The pretrial proceedings included four declarations of doubt about Adams's competency. Judge Kevin P. Stennis declared the first doubt on November 3, 2023; Judge Yvette Verastegui declared the second on December 22, 2023; and Stennis declared the third and fourth on January 31 and April 24, 2024. Dr. Kory J. Knapke concluded in December 2023 that Adams was malingering and competent, and Judge Maria Cavalluzzi reinstated proceedings based on that report. Dr. David Rad's January 2024 evaluation was inconclusive; Cavalluzzi nevertheless reinstated proceedings on January 5, 2024, based on Knapke's earlier report. Dr. George R. Elias, retained by the defense, concluded Adams was incompetent; his report was not filed, but counsel informed the court of its conclusion at the January 31 and April 24, 2024 hearings.
Knapke reevaluated Adams in March 2024 and again found malingering and competency. After Stennis required a different evaluator, Dr. Sharon L. Guo concluded in May 2024 that Adams was unwilling rather than unable to cooperate and was competent. At trial, Adams invoked his Faretta rights; the court initially denied the request as untimely, then granted it after admonishment. He represented himself, cross-examined witnesses, and delivered closing argument. At the August 28, 2024 sentencing, the defense submitted Elias's report. The court imposed an aggregate 10-year sentence and struck the firearm enhancements for counts 2 through 4.
The Court’s Holding
The Court of Appeal rejected Adams's ineffective-assistance claim without deciding whether counsel performed deficiently. It assumed deficient performance and held that Adams showed no reasonable probability of a different competency outcome. Stennis had accepted counsel's description of Elias's conclusion in January 2024, declared a doubt, and ordered further proceedings. The mental health court later ordered reevaluation, and after Knapke's second report, ordered Guo's independent evaluation. The court reasoned that Adams received the further evaluations he sought and that it was speculative that earlier submission of Elias's report would have produced an incompetency finding. Five court-appointed experts evaluated him, and only the defense-retained Elias reached that conclusion.
The court also held that Stennis did not err by sentencing without declaring another doubt. A new hearing after a competency finding requires a substantial change of circumstances or new evidence casting serious doubt on the earlier finding. Stennis had known Elias's conclusion for months, twice relied on it to order further evaluation, and possessed the more recent Knapke and Guo reports supporting competency. The appellate court found substantial evidence supporting the implied determination that the report was not new evidence requiring renewed proceedings and no abuse of discretion in proceeding with sentencing.
The court agreed that the sentencing minute order and abstract of judgment inaccurately omitted the waiver of the $400 parole revocation fine. Although both documents reflected waiver of the $400 restitution fine and the $30 and $40 assessments, the oral pronouncement also waived the parole revocation fine. The judgment was affirmed, with remand directions to correct both records, issue an amended abstract, and send a certified copy to the Department of Corrections and Rehabilitation.
Key Takeaways
- An appellate court may reject an ineffective-assistance claim for lack of prejudice without deciding whether counsel's performance was deficient.
- Repeated competency evaluations and the relief already granted to the defendant were central to the court's conclusion that earlier submission of the defense report would not probably have changed the outcome.
- After a defendant has been found competent, an expert's contrary opinion does not automatically require another hearing without changed circumstances or genuinely new evidence casting serious doubt on that finding.
- The court treated Adams's active self-representation at trial as inconsistent with his claim of prejudice, noting that he persuaded the court he was capable of representing himself and that his conduct belied Elias's incompetency conclusion.
- The only relief granted was correction of the sentencing minute order and abstract of judgment to include the waived $400 parole revocation fine; the convictions and sentence otherwise remained affirmed.
Why It Matters
The decision illustrates how prejudice analysis can defeat an ineffective-assistance claim even when an appellate court assumes deficient performance. The sequence of hearings mattered: the trial judge already knew the defense expert's conclusion, repeatedly ordered further evaluation, and ultimately relied on later independent reports. The opinion also emphasizes the distinction between an initial competency inquiry and a request to reopen competency after a formal finding.
The remand is limited to making the written sentencing records match the oral waiver of fines and fees. It does not disturb the robbery convictions, firearm finding, or aggregate sentence. The opinion is not certified for publication and is subject to California's restrictions on citing unpublished appellate decisions.