O'BRIEN v. Superior Court

61 Cal. App. 3d 62, 132 Cal. Rptr. 13, 1976 Cal. App. LEXIS 1796
CourtCalifornia Court of Appeal
DecidedAugust 16, 1976
DocketDocket Nos. 15715, 15729, 15740, 15786
StatusPublished
Cited by13 cases

This text of 61 Cal. App. 3d 62 (O'BRIEN v. Superior Court) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'BRIEN v. Superior Court, 61 Cal. App. 3d 62, 132 Cal. Rptr. 13, 1976 Cal. App. LEXIS 1796 (Cal. Ct. App. 1976).

Opinion

*65 Opinion

GARDNER, P. J.

These four writ proceedings present a common issue: Whether there is a right to jury trial in a habeas corpus proceeding brought by a person civilly committed as mentally retarded pursuant to Welfare and Institutions Code section 6500 et seq.

In 4 Civil 15715 the Medical Director of Patton State Hospital and the State Department of Health seek a writ of prohibition to prevent the superior court from granting jury trials to five persons involuntarily confined in Patton State Hospital as mentally retarded persons pursuant to Welfare and Institutions Code section 6500 et seq. Each of these five persons instituted habeas corpus proceedings in the superior court seeking release from custody. The question of their right to jury trial was briefed and argued in superior court. The judge granted the motion for jury trial in each case and the instant writ proceeding is in effect an interlocutory appeal from those orders. However, the Attorney General has informed us that four of the proceedings below have now been dismissed following the release of the persons concerned, and therefore as to these proceedings the petition is moot. We treat this declaration as a motion to amend the petition to delete reference to the dismissed proceedings, which we grant.

Numbers 4 Civil 15729, 4 Civil 15740, and 4 Civil 15786, are petitions for writs of habeas corpus by three other persons confined in Patton State Hospital as mentally retarded persons. These petitioners each filed a prior habeas petition in the superior court which was heard without a jury and denied. We granted alternative writs and issued orders to show cause for the limited purpose of determining whether the Superior Court acted within its jurisdiction in denying the petitions without affording the option of jury trial. Two of these three petitioners have now been released from Patton State Hospital and therefore have already received the relief requested. Motions to dismiss their petitions for habeas corpus have been filed by the Attorney General on the ground of mootness. Although petitioners’ counsel urges us to apply the public interest exception to the mootness doctrine (see 6 Witkin, Cal. Procedure (2d ed.) Appeal, § 470), there is no need to apply that exception here because the questions raised in the moot petitions are also raised by the remaining petition for habeas corpus and by the amended petition for writ of prohibition. Accordingly, mootness is a sufficient ground for denying the writs of habeas corpus in numbers 4 Civil 15729 and 4 Civil 15740. (See People v. Daniels, 14 Cal.3d 857, 863 [122 Cal.Rptr. 872, 537 P.2d 1232].)

*66 Resolution of the issue before us requires a brief review of statutory provisions governing involuntary commitment of the mentally retarded and decision of certain preliminary questions concerning their operation.

Prior to July 1, 1971, a person could be committed to a state hospital for an indefinite period upon a finding of mental retardation. (See generally, Legal Planning for the Mentally Retarded: The California Experience, 60 Cal.L.Rev. 438.) On and after July 1, 1971, no mentally retarded person may be committed unless it is also shown that he or she is a danger to self or others. (Welf. & Inst. Code, § 6500.1.) Also, beginning January 1, 1976, the effective date of the most recent amendment to Welfare and Institutions Code section 6500.1, 1 any order committing a mentally retarded person expires automatically one year after the order of commitment is made.

I

The first question presented is whether commitment orders made prior to January 1, 1976, continue to be effective as indefinite commitments, or whether such orders are subject to expiration.

We are informed by the Attorney General, acting on behalf of the State Department of Health, that the Second District Court of Appeal has concluded, in an unpublished opinion, that orders entered prior to January 1, 1976, are subject to expiration. We are in agreement with this conclusion. The most reasonable and logical interpretation of the statutory language (see fn. 1, ante) is that complete coverage was intended; i.e., that the provision for expiration applies to all commitments, and not just commitments made after the effective date of the amendment. Moreover, a different interpretation would raise serious constitutional questions. Under the equal protection clauses of the *67 California and federal Constitutions, statutes which affect fundamental interests must be applied uniformly unless classification is necessary to further some compelling state interest. (See In re Gary W., 5 Cal.3d 296, 306 [96 Cal.Rptr. 1, 486 P.2d 1201]; In re Kapperman, 11 Cal.3d 542, 545 [114 Cal.Rptr. 97, 522 P.2d 657].) The distinction between indefinite commitment and commitment for a single year substantially involves the fundamental interest of personal liberty, and therefore it would appear that the state would be required to demonstrate that different treatment of persons according to their commitment date was necessary to further a compelling state interest. There is also some question whether indefinite commitment of the mentally retarded would satisfy the requirements of due process of law. (See Jackson v. Indiana, 406 U.S. 715 [32 L.Ed.2d 435, 92 S.Ct. 1845]; People v. Feagley, 14 Cal.3d 338, 358-376 [121 Cal.Rptr. 509, 535 P.2d 373]; In re Davis, 8 Cal.3d 798, 803-805 [106 Cal.Rptr. 178, 505 P.2d 1018].) In view of these serious difficulties, and the willingness of the Attorney General to concede that pre-1976 commitments are subject to expiration, we construe Welfare and Institutions Code section 6500.1 to so provide.

II

A related question is when pre-1976 commitments expire. It is inconceivable that the Legislature intended all such commitments to expire January 1, 1976. The cardinal rule of construction is that statutes are to be interpreted to produce a reasonable result. (Alford v. Pierno, 27 Cal.App.3d 682, 688 [104 Cal.Rptr. 110].) Accordingly, to allow a sufficient interval for orderly transition, we construe the statute as providing for expiration of all pre-1976 orders on January 1, 1977, one year from the effective date of the statute.

We understand that the state, quite properly, has begun a review of aL pre-1976 commitments and that recommitment proceedings have begun in a number of instances. Thus it is hoped that the state will have completed its review by January 1, 1977. Any person committed prior to 1976 who has not been recommitted by that date will be entitled to release which may be obtained by a proceeding in habeas corpus.

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Cite This Page — Counsel Stack

Bluebook (online)
61 Cal. App. 3d 62, 132 Cal. Rptr. 13, 1976 Cal. App. LEXIS 1796, Counsel Stack Legal Research, https://law.counselstack.com/opinion/obrien-v-superior-court-calctapp-1976.