Sgaraglino v. County of Ventura (June 8, 2026, B348978) __ Cal.App.5th __, 2026 WL 1657823
Anthony Sgaraglino was involuntarily detained for psychiatric care at Ventura County Medical Center under Welfare and Institutions Code section 5150. He was discharged after a physician determined he no longer met the criteria for continued hospitalization. Sgaraglino committed suicide the next day. His parents sued Ventura County for wrongful death, alleging negligence or gross negligence in releasing him despite indications he was unsafe to discharge. The County moved for summary judgment, asserting immunity under section 5113. The Sgaraglinos argued section 5113 does not apply to gross negligence claims, but they filed no responsive separate statement—only a doctor’s declaration opining that Anthony should not have been released given his history of mental illness and suicidal ideation. The trial court granted the motion, finding section 5113 barred any claim that the release fell below the standard of care. The Sgaraglinos appealed.
The Court of Appeal affirmed, holding that section 5113 grants psychiatric facilities immunity for releasing patients after a section 5150 involuntary detention. The court explained that the Lanterman-Petris-Short Act, which governs involuntary detention of persons with mental illness, was enacted to end inappropriate, indefinite, and involuntary commitment. Immunity furthers the Act’s goals. Recognizing the tension between safety and freedom, the Legislature imposed time limits on involuntary detentions and immunized psychiatric facilities and their personnel from liability for release decisions. Section 5113 provides that a facility “shall not be civilly or criminally liable for any action by a person released at or before the end of a period for which the person was admitted.” On its face, section 5113 protects the County from liability for Sgaraglino’s post-release actions, and the statute contains no exception for gross negligence. Because the Sgaraglinos did not dispute in a responsive separate statement that Anthony no longer met the criteria for continued hospitalization, the doctor’s declaration was irrelevant. Arguing the release did not meet the medical standard of care is the very argument section 5113 forecloses.
