California Legal Brief

The Rule of People v. Chhuon and Pan is that defense counsel cannot concede a defendant's guilt to any crime over the defendant's express objection to maintain innocence, even as part of an alternative argument strategy, under circumstances where the defendant expressly instructs counsel not to admit guilt and counsel nevertheless argues the defendant is guilty of lesser charges to avoid the death penalty.

The Rule of People v. Bertsch and Hronis is that a defendant's extreme religious beliefs alone do not render him mentally incompetent under Penal Code section 1367 if he is unwilling, rather than unable, to cooperate with counsel, under circumstances where the defendant understands the proceedings and can rationally assist in his defense despite his religious convictions.