Does the record support a defendant's contention that the court erred in failing to hold a second competency hearing prior to sentencing?

Moreover, the record does not support defendant's contention the court erred in failing to hold a second competency hearing prior to sentencing. " '[W]hen a competency hearing has already been held and the defendant has been found competent to stand trial . . . a trial court need not suspend proceedings to conduct a second competency hearing unless it "is presented with a substantial change of circumstances or with new evidence" casting a serious doubt on the validity of that finding.' " (People v. Mendoza (2016) 62 Cal.4th 856, 884.) " '[T]he trial court may appropriately take its personal observations into account in determining whether there has been some significant change in the defendant's mental state.' " (Id. at p. 885.)

Defendant contends the record demonstrates she was acting in a manner that warranted a second competency hearing. A similar argument was raised and rejected in People v. Hightower (1996) 41 Cal.App.4th 1108. The defendant there engaged in "disruptive behavior in the courtroom" and regular "disputes with defense counsel." (Id. at p. 1112.) Hightower explained that " '[t]he test, in a [Penal Code] section 1368 proceeding, is competency to cooperate, not cooperation.' " (Ibid.)

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