California Appeals Court Reverses Conviction Over Denied Continuance
In People v. Seigler (Cal. Ct. App., Oct. 31, 2025, No. A170503) 2025 WL 3442653 the First District Court of Appeal reversed a conviction because the defendant was denied a continuance that he needed to present evidence of mental health challenges.
The appeals court found that the trial court committed abuse of discretion in denying defense counsel’s motion to continue. The motion was based upon the assertion that the dfeense needed time for an expert examination in support of mental health diversion request (PC 1001.36). The Court of Appeal found that the denial of the continuance deprived defendant of a fair hearing on his mental health diversion application made pursuant to Penal Code section 1001.36 request. It forced him to choose between a guilty plea (which is what he did) and trial with an unprepared attorney.
The court ruled that a trial judge abused their discretion by denying a last-minute continuance request, effectively stripping defendant Anthony Seigler of his right to a fair shot at mental health diversion. This decision not only reverses Seigler's plea and sentence but underscores the critical need for courts to accommodate evaluations under California's mental health diversion statute (Penal Code § 1001.36). For defendants grappling with addiction and mental illness, it's a beacon of hope—and a wake-up call for the system.
The Chaotic Backstory: Paranoia, Bullets, and Burglary
Anthony Seigler's troubles began in March 2023 in a haze of paranoia and substance abuse. He and his girlfriend, Katrina Fowles, frantically called 911, claiming unknown assailants were banging on their walls, threatening their young son, and even firing shots into their home. When police arrived, they found no evidence of any intruders or gunfire from outside—just Seigler and Fowles exhibiting classic signs of intoxication: dilated pupils, twitching, and wild delusions.
The real danger? Seigler had fired two rounds through his bathroom wall while his son was bathing in the tub nearby. No one was hurt, but the incident led to charges of negligent discharge of a firearm (Penal Code § 246.3).
The drama escalated a month later. Seigler and Fowles were arrested for burglarizing Fowles's mother's home while she was out of town. Prosecutors tacked on burglary charges (Penal Code § 459) and other counts, consolidating the cases for trial. Seigler's behavior screamed untreated mental health issues intertwined with severe drug addiction—issues that defense counsel flagged early but that the court ultimately sidelined in a rush to judgment.
From the prosecution point of view the discharge of the firearm endangered a child. They were less sympathetic of the defendant than they might have been under other circumstances.
Procedural Rollercoaster: Continuances Granted, Then Stonewalled
Seigler's case dragged through pretrial proceedings, with multiple continuances already approved for reasons like witness unavailability, late discovery, and his codefendant's new attorney. Trial was postponed from August 2023 to February 7, 2024. As early as August 2023, defense counsel had raised red flags, filing a motion for continuance specifically to evaluate Seigler for mental health diversion. In a sworn declaration, counsel described Seigler as "delusional" and in the grips of "severe drug addiction, or mental disease, or both," emphasizing the need to "preserve my ability to file a Petition for Mental Health Diversion."
That initial request was granted, but no evaluation ever happened—likely due to logistical hurdles like securing funding for an expert. Fast-forward to February 7, 2024: trial day. With jury selection looming, defense counsel sprang into action. They filed a formal motion to continue under Penal Code § 1050 (requiring "good cause" for delays) and an application for mental health diversion under § 1001.36. The pitch? Funding for an expert evaluator was now in place, but more time was needed to assess Seigler's eligibility. Counsel candidly admitted: Seigler was "not prepared to go forward" with trial.
The trial court wasn't having it. In a blunt denial, the judge declared: "I don’t find good cause to continue the trial in these cases. There’s nothing that’s been presented that the defendant is eligible for mental health diversion. There’s no diligence in filing the motion on the day of trial and filing the application on the day of trial. So for those reasons, good cause has not been shown. The motion to continue is denied in each case."
The diversion application fared no better. Citing procedural rules requiring 10 court days' notice, the court dismissed it outright: "This is an application. Any motions have to be filed ten court days in advance of the hearing... based on the late filing, I find this application has no merit. Even if [rule] 4.111 subdivision (b) did not apply, I’m not granting the application because the People weren’t given notice. In addition, this application simply states that the defendant understands certain aspects of the program... Nothing has been presented to show that any of the elements... are required for eligibility for mental health diversion."
Jury selection began immediately. Cornered, Seigler entered no-contest pleas to the negligent discharge and burglary charges, landing two years of formal probation. No treatment. No second chance. Just a conviction that could haunt him forever.
The Appeal: Abuse of Discretion That "Forced a Hobson's Choice"
Seigler appealed, arguing the denial of the continuance was an abuse of discretion under § 1050. The appellate court agreed—unanimously and emphatically. Reviewing the record, the panel (authored by Justice Alison E. Bartlett, with Justices Jennifer K. Rockwell and Peter J. Mullan concurring) applied the familiar multi-factor test for continuances: (1) defendant's diligence, (2) anticipated benefits, (3) burden on others (like witnesses or the court), and (4) whether denying it would undermine "substantial justice."
On diligence, the court acknowledged the day-of filing looked bad but wasn't fatal. Mental health concerns had been on the radar since August 2023, and counsel had hustled to secure funding. More importantly, the trial judge never probed for "good cause" under § 1050—skipping the required inquiry into why the delay happened.
The benefits? Monumental. A continuance would have allowed an expert exam to determine if Seigler's substance-induced mental disorder qualified him for diversion under § 1001.36, which lets eligible defendants avoid conviction by completing treatment. The statute requires showing a mental disorder contributed to the crime and that treatment is feasible—precisely what an evaluation could prove. Without it, Seigler got no "merits hearing" on diversion, dooming his application on technicalities.
As for burdens, the prosecution couldn't point to any: Jury selection hadn't started, and no witnesses were inconvenienced. The real injustice? The denial "deprived defendant of a merits hearing on his § 1001.36 request and forced him to choose between a guilty plea and trial with an admittedly unprepared attorney." That's a Hobson's choice—illusory options that railroad defendants into pleas without exploring life-changing alternatives like treatment and dismissal.
In short, the court found the denial not just erroneous, but prejudicial: It tainted the entire proceeding, rendering the pleas involuntary.
The Bottom Line: Reversal, Remand, and a Path to Redemption
The appellate court's holding is a clean sweep: Seigler's judgment—pleas and all—is reversed. On remand, he's entitled to a "reasonable opportunity" to file (and actually litigate) a § 1001.36 application. If granted and he completes treatment? Charges dismissed, conviction erased. If not?
The original judgment can be reinstated.
This isn't just a win for Seigler; it's a blueprint for defense attorneys everywhere. Courts must weigh mental health diversion seriously, even if it means pausing the trial calendar. As California grapples with overcrowded prisons and a mental health crisis, People v. Seigler reminds us: True justice heals, it doesn't just punish.
If you are facing criminal prosecution, mental health diversion is an option for some people. The lawyers at the Law Office of Daniel Horowitz are certified as specialists by the State Bar of California Board of Legal Specialization. Call us for an initial consultation. (925) 283-1863
