Reed v. Super. Ct.

CourtCalifornia Court of Appeal
DecidedDecember 30, 2025
DocketA173393
StatusPublished

This text of Reed v. Super. Ct. (Reed v. Super. Ct.) 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
Reed v. Super. Ct., (Cal. Ct. App. 2025).

Opinion

Filed 12/30/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

BEAU REED, Petitioner, v. THE SUPERIOR COURT OF A173339 SOLANO COUNTY, (Solano County Respondent; Super. Ct. Nos. F25-00216, THE PEOPLE, F25-00429, F24-02766) Real Party in Interest.

In 2024, the voters passed Proposition 36, “The Homelessness, Drug Addiction, and Theft Reduction Act.” (Prop. 36, as approved by voters Gen Elec. (Nov. 5, 2024) (Prop. 36).) Among other things, Proposition 36 added Health and Safety Code1 section 11395, creating the offense of possession of a hard drug with two prior drug-related convictions and providing a postconviction treatment option for defendants who elect to plead guilty or no contest to a section 11395 charge. (§ 11395, subds. (b)(1), (c), (d)(1)–(2).) The issue in this writ of mandate proceeding is whether a trial court has discretion to grant pretrial mental health

1 All further statutory references are to the Health and

Safety Code unless otherwise specified.

1 diversion under Penal Code section 1001.36 (hereafter, pretrial mental health diversion) to a defendant charged with violating section 11395. The People maintain that section 11395 precludes defendants charged thereunder from participating in pretrial mental health diversion as a matter of law. The trial court agreed and ruled that petitioner was ineligible for pretrial mental health diversion in two cases where he was charged solely under section 11395. We conclude that a defendant charged under section 11395 is not precluded from participating in pretrial mental health diversion. We will direct the trial court to vacate its order denying petitioner’s requests for pretrial mental health diversion and direct the court to reconsider petitioner’s requests under Penal Code section 1001.36. BACKGROUND This matter involves three criminal cases. In case No. F24- 02766, petitioner was charged with possession for sale of a controlled substance (§ 11378) for an incident that occurred in May 2023. In case No. F25-00216, petitioner was charged with possession of a hard drug with two prior convictions (§ 11395, subd. (b)(1) (section 11395(b)(1))) for an incident that occurred on January 28, 2025. And in case No. F25-00429, petitioner was charged with possession of a hard drug with two prior convictions under section 11395(b)(1) for an incident that occurred on January 6, 2025. Petitioner filed a motion for pretrial mental health diversion and for treatment pursuant to section 11395.

2 At the hearing on petitioner’s motion, his counsel explained that, because not all of petitioner’s pending charges qualified for treatment under section 11395, petitioner was requesting treatment under section 11395 and pretrial mental health diversion. Counsel argued that petitioner qualified for pretrial mental health diversion as to all charges because he had a qualifying diagnosis and because he would be a suitable candidate. The People responded that, because section 11395 applied “[n]otwithstanding any other laws,” the drug treatment provision therein applied to petitioner’s section 11395 offenses to the exclusion of pretrial mental health diversion. The People further argued that section 11395 conflicted with Penal Code section 1001.36 because pretrial mental health diversion provided for a pre-conviction pathway that allowed defendants to avoid the need to enter a plea to be eligible for treatment under section 11395. The court concluded that petitioner was not eligible for pretrial mental health diversion as to the two cases charging violations of section 11395. The court reasoned, “Substance use disorder is a named mental health diagnosis in the [Diagnostic and Statistical Manual of Mental Disorders]. So there is a strong argument to be made that if you’re kind of doing the Venn diagram, if you’re eligible for treatment [under section 11395], you would automatically be eligible for [pretrial] mental health diversion as well, which would make the treatment mandated felony provision of 11395 moot and surplusage, and I don’t find that to be the intent of the [L]egislature. [¶] I find that their

3 intent was that they recognize the societal problem and have tried to create a public policy direction to address this, and they did that after the implementation of [pretrial] mental health diversion. [¶] And so, I find that [section] 11395 takes precedence and notwithstanding any other law, but that’s simply for the cases where 11395 is charged. I find [petitioner is] ineligible for [pretrial] mental health diversion in those cases.” The court subsequently clarified that it was not ruling on the merits of petitioner’s eligibility for pretrial mental health diversion on the section 11395 charges because pretrial mental health diversion was “barred by law” on those charges. Petitioner’s counsel then asked the court to rule on petitioner’s suitability and eligibility for pretrial mental health diversion as to the section 11378 charge in case No. F24-02766, and the court granted petitioner’s request for pretrial mental health diversion in that case. After the trial court denied a motion for reconsideration, petitioner filed this petition for writ of mandate. We requested a preliminary opposition to the petition and issued an order to show cause why the relief requested in the petition should not be granted. We also granted permission to amici curiae, the Office of the State Public Defender, California Public Defenders Association, and California Attorneys for Criminal Justice, to file a brief in support of petitioner. DISCUSSION The controlling issue in this writ proceeding — the interplay between section 11395 and Penal Code section 1001.36

4 — is a question of statutory interpretation subject to our de novo review. (People v. Superior Court (Ortiz) (2022) 81 Cal.App.5th 851, 862 (Ortiz).) We begin by describing the statutes at issue. A. Penal Code Section 1001.36 The Legislature enacted Penal Code section 1001.36 in 2018 to create a pretrial mental health diversion program for defendants with diagnosed mental health disorders. (Stats. 2018, ch. 34, § 24.)2 Pretrial mental health diversion “ ‘allows for the suspension of criminal proceedings and potential dismissal of charges upon successful completion of mental health treatment.’ ” (Vaughn v. Superior Court (2024) 105 Cal.App.5th 124, 133; see Pen. Code, § 1001.36, subd. (f)(1) [“ ‘[p]retrial diversion’ means postponement of prosecution . . . at any point in the judicial process from the point at which the accused is charged until adjudication, to allow the defendant to undergo mental health treatment”].) Pretrial mental health diversion requires findings that a defendant is eligible for diversion and suitable for the program. (Sarmiento v. Superior Court (2024) 98 Cal.App.5th 882, 891.) A defendant is eligible for pretrial mental health diversion if he or she has been diagnosed by a qualified mental health expert with a mental disorder “as identified in the most recent edition of the Diagnostic and Statistical Manual of Mental Disorders” (DSM) and that mental disorder was a significant factor in the

2 The Legislature substantially amended Penal Code

section 1001.36 in 2023. (Stats. 2023, ch. 687, § 1.2.) Our analysis rests on the current version of the statute.

5 commission of the criminal offense with which the defendant is charged. (Pen. Code, § 1001.36, subd. (b)(1)–(2).) A defendant is suitable if (1) a qualified mental health expert opines the mental disorder would respond to treatment, (2) the defendant agrees to waive speedy trial rights, (3) the defendant agrees to comply with treatment requirements, and (4) the defendant will not pose an “unreasonable risk of danger to public safety” as defined in Penal Code sections 1170.18 and 667, subdivision (e)(2). (Pen Code, § 1001.36, subd.

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Reed v. Super. Ct., Counsel Stack Legal Research, https://law.counselstack.com/opinion/reed-v-super-ct-calctapp-2025.