People v. Stanley

In People v. Stanley (1995) 10 Cal.4th 764, during the penalty phase of the trial, trial counsel advised the court they thought Stanley might be incompetent to rationally assist in his defense. (Stanley, supra, 10 Cal.4th at pp. 802-803.) Stanley initially objected to the competency hearing, then withdrew his objection. The trial court asked Stanley if he wanted the court to appoint another attorney to represent him in connection with the competency proceedings, and he indicated he did. (Ibid.) Trial counsel presented evidence of defendant's incompetence, and the newly appointed attorney presented evidence of defendant's competence. (Ibid.) On appeal, Stanley argued the trial court erred in appointing additional counsel on the issue of competence, thereby creating a conflict between his lawyers, which deprived him of due process. ( Stanley, supra, 10 Cal.4th at pp. 803-804.) In rejecting this claim, the Supreme Court stated, "In appointing separate counsel to represent defendant's point of view, the trial court acted to resolve a conflict, not create one. In so doing it permitted the jury to hear every side of the issue of defendant's competence, thereby assuring defendant a fair trial. In the circumstances, defendant perhaps got more than he was entitled to." ( Id. at pp. 806-807.) In People v. Stanley (1995) the defendant asserted he killed his wife for love after she filed charges against him. The court rejected the defendant's claim that the jury should have been instructed that to find the special circumstance true, they would have to find the "predominant purpose" of the killing was to prevent his wife's testimony. The court held: "If the defendant intentionally kills a would-be witness for the purpose of preventing the victim from testifying in a criminal proceeding, it is not a defense to the special circumstance allegation that he had another purpose as well." ( Id. at p. 801, 42 Cal. Rptr. 2d 543, 897 P.2d 481.)