Sufficient Sleep on the Night Before Prisoners Trial

In People v. Smith (1985) 38 Cal.3d 945, the Supreme Court rejected a jailed defendant's claim that he was not given an opportunity to get sufficient sleep on the night before his trial, concluding that the defendant's position was "unsupported both factually and legally." (Id. at p. 953.) The Smith court noted that the defendant's reliance on cases involving challenges to jail conditions did not support the defendant's assertion that the court should have either held a hearing to determine whether the defendant had been given the opportunity to get eight hours of sleep, or suspended the trial. (Id at. p. 955.) In the cases on which Smith was relying, the courts were concerned "not with affording prisoners the opportunity for eight hours of sleep, but ensuring that no defendant 'is so worn out . . . that he lacks the alertness to help his attorney or to try to "put his best foot forward" in the presence of the trier of fact.'" (Id. at pp. 955-956.)