California Supreme Court

Reynaldo A. Maldonado, Petitioner v. the Superior Court of San Mateo County, Respondent; the People, Real Party In…

April 23, 201253 Cal. 4th 1112

Summary

The court held that a defendant who gives notice of an intended mental-state defense may be compelled to undergo prosecution-ordered mental examinations and must permit the prosecution full pretrial access to the examination results. The Fifth Amendment requires protection against direct or derivative use of compelled statements except as necessary to rebut the mental-state defense, but it does not generally require delayed disclosure, prosecutorial exclusion from examinations, or pretrial in camera redaction; the Sixth Amendment likewise does not require those protections. Justice Liu, concurring, agreed with the result but emphasized that trial courts retain discretion to impose case-specific protections against misuse.