Hollywood Killer's Conviction Overturned

LOS ANGELES, CA — The California Supreme Court Monday directed an appeals court to reverse the conviction of a state prison inmate serving a life sentence for the 2009 murder of a homeless man and two related stabbings in Hollywood, based on issues of mental competency.

California's highest court held that the trial court failed to appropriately assess Domingo Rodas' competency to stand trial given his history of psychosis and the fact that he had stopped taking medication.

Rodas, who was born Doudley Brown, was charged with stabbing three men to death and trying to kill two others. All of the men had been living on the street and four of the five stabbings happened within a few hours in the same area of Hollywood, according to court documents. Rodas was arrested in the area carrying a knife, and DNA from three of the victims was found on the weapon, its sheath or Rodas' shirt.

He was convicted in 2014 of killing Keith Fallin -- jurors found true a special circumstance allegation of lying in wait -- and was also found guilty of attempting to murder two other homeless men, Kenneth McFetridge and Ronald Vaughn. The jury acquitted Rodas of murder charges in the deaths of Frederick Lombardo and Roger Cota.

Rodas, who was identified by one of the surviving victims, was sentenced to life in prison without the possibility of parole, plus two additional life terms.

The defendant had a history of mental illness dating back to at least 1974, when he was treated in an army hospital at the age of 19 for a unspecified psychiatric disorder. He ultimately received a medical discharge from the military, according to court documents.

In 1988, after serving a prison sentence for burglary, Rodas was held under a mental health conservatorship at Atascadero and Patton state hospitals. He was diagnosed with schizophrenia, paranoid type and schizoaffective disorder with substance abuse, according to the court.

When charged with the homeless murders, Rodas was initially found incompetent to stand trial and was sent back to Patton State Hospital for several months. After treatment with antipsychotic medication, doctors reported he had regained competence but must continue taking the medication. But by the time of trial, Rodas had stopped taking the meds and was incoherent in conversations with his lawyer, who declared a doubt about his competence.

The judge quizzed Rodas, who was able to identify the charges against him and said he was ready for trial. The defendant also disclosed that he wasn't taking his medication and was "doing fine" without it.

The judge ruled that the trial could proceed.

Rodas later took the stand in his own defense, against his attorney's advice, and his testimony was incoherent, according to court documents.

An appeals court upheld Rodas' conviction, agreeing with the trial judge that his responses before trial began indicated he was competent and could help his lawyer in her defense.

The California Supreme Court disagreed, saying the trial judge should have stopped proceedings and set a formal hearing to determine competence.

Its ruling states that "when a formerly incompetent defendant has been restored to competence solely or primarily through administration of medication, evidence that the defendant is no longer taking his medication and is again exhibiting signs of incompetence will generally establish such a change in circumstances and will call for additional, formal investigation before trial may proceed."

"In the face of such evidence, a trial court's failure to suspend proceedings violates the constitutional guarantee of due process in criminal trials," Justice Leondra R. Kruger wrote in the court's opinion.

Former and current attorneys general, Kamala Harris and Xavier Becerra, had argued that if the court came to that conclusion, it should allow for a retrospective hearing to determine Rodas' competency at the time of trial rather than directing the conviction to be overturned.

The state's high court ruled that such a hearing would be unreliable given changes over time in the defendant's mental condition. The opinion states that Rodas may be retried on the charges on which he was convicted if he is also found competent to stand trial at that time.

By ELIZABETH MARCELLINO, City News Service; Photo: Shutterstock