California v. Superior Court (Frezier)
Annotate this CaseIn October 2019, Christopher Frezier was found not guilty by reason of insanity of a felony offense. The trial court committed him to a state hospital pursuant to Penal Code section 1026. At the time of the commitment, the trial court calculated Frezier’s maximum term of commitment as three years with credits for 829 days, consisting of credits for both the actual time served in custody prior to his commitment and conduct credits pursuant to section 4019 for the time spent in county jail. Despite his commitment to a state hospital to receive treatment, Frezier was never transported to a hospital and instead, was left in the county jail for unknown reasons. After spending almost one year in jail after his commitment, Frezier filed a petition for writ of habeas corpus asserting that he was entitled to immediate release because he had served his maximum term of commitment, after accounting for his precommitment custody and conduct credits combined with the additional time served in the county jail postcommitment. The trial court agreed and granted relief, ordering that Frezier be released. The District Attorney sought extraordinary relief and an immediate stay to prevent Frezier’s release by petitioning for a writ of mandate. The District Attorney argued Frezier was not entitled to section 4019 conduct credits under the relevant statutes. The Court of Appeal concluded that under the plain language of the relevant statutes, Frezier served more than his maximum term of commitment and the District Attorney failed to demonstrate any error warranting extraordinary relief. The Court, therefore, denied the District Attorney’s writ petition.
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