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.
February 5, 2026
Court of Appeal of the State of California, Fourth Appellate District, Division Two
The Rule of Esparza v. The Superior Court of San Bernardino County is that incompetence to testify under Evidence Code section 701 may not be presumed from a prior grave disability finding under the LPS Act, under circumstances where a conservatorship has been established based on inability to provide for basic personal needs.
January 28, 2026
Court of Appeal, Second Appellate District, Division Four
The Rule of Conservatorship of B.K. is that an LPS Act conservatee may waive their jury trial right through counsel without a personal on-the-record advisement when the conservatee acknowledges awareness of the right and confirms the waiver choice, under circumstances where counsel has consulted with the conservatee, there is no suggestion counsel lacks authority or disregards the client's wishes, and the conservatee participates in the proceedings without objection.