California Legal Brief

The Rule of Sgaraglino v. County of Ventura is that Welfare and Institutions Code section 5113 immunizes psychiatric facilities from civil liability for any action by a patient released after involuntary detention, even when the release decision allegedly constitutes gross negligence, under circumstances where the patient was involuntarily detained under section 5150 and released at or before the end of the authorized detention period.

Appeal from order granting summary judgment in Superior Court, Ventura County.

Plaintiff Appellants were Franklin and Linda Sgaraglino — parents of Anthony Sgaraglino who died by suicide one day after discharge from involuntary psychiatric detention.

Defendant Respondent was County of Ventura — operator of Ventura County Medical Center's inpatient psychiatric unit that discharged Anthony.

The suit sounded in wrongful death based on general negligence. No cross-claims were applicable.

The key substantive facts leading to the suit were Anthony Sgaraglino was involuntarily detained at Hillmont psychiatric unit under section 5150 on January 6, 2023, diagnosed with bipolar disorder, discharged three days later when a physician determined he did not meet criteria for continued hospitalization under section 5250, and took his own life on January 10, 2023. Appellants alleged they told hospital staff Anthony was suicidal and tried to continue his commitment, but he was released without medication despite indications he might be suicidal.

The procedural result leading to the Appeal: The trial court granted summary judgment in favor of the county, ruling that section 5113 barred any claim that respondent's treatment and release of Anthony fell below the standard of care and that there was no authority supporting appellants' contention that immunity did not apply to gross negligence claims.

The key question(s) on Appeal: 1. Whether Welfare and Institutions Code section 5113 immunizes psychiatric facilities from liability for post-release patient actions even in cases of alleged gross negligence. 2. Whether new theories of liability under federal civil rights law, the Bane Act, and Tarasoff can be raised for the first time on appeal.

The Appellate Court held that section 5113 provides complete immunity to psychiatric facilities for any action by a person released at or before the end of the authorized detention period, contains no exception for gross negligence, and bars claims challenging the adequacy of release decisions even when based on allegations that the patient was discharged despite indications of continued danger.

The case is inapplicable when the alleged negligence occurs during treatment while the patient remains detained at the facility (rather than relating to the release decision), when the patient was not subject to involuntary detention under the LPS Act, or when harm occurs before or during the detention period rather than after release.

The case leaves open whether appellants may file a new complaint against potential unnamed defendants not protected by section 5113 immunity, and does not address the scope of immunity for other types of LPS Act detentions beyond section 5150.