June 8, 2026
Court of Appeal, Second Appellate District, Division Six
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.
December 30, 2025
Court of Appeal of the State of California, First Appellate District, Division Four
The Rule of Vallejo City Unified School District v. Superior Court is that a school district is immune from liability under Education Code section 44808 for harm to parents caused by a student's off-campus suicide, under circumstances where the student was not and should not have been under the immediate and direct supervision of district employees at the time of death, even if the district was allegedly negligent in its on-campus supervision and response to the student's mental health crisis.