Siam v. Superior Court

CourtCalifornia Court of Appeal
DecidedJanuary 26, 2026
DocketG065447
StatusPublished

This text of Siam v. Superior Court (Siam 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
Siam v. Superior Court, (Cal. Ct. App. 2026).

Opinion

Filed 1/26/26

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FOURTH APPELLATE DISTRICT

DIVISION THREE

JOEL PRANEET SIAM,

Petitioner,

v. G065447

THE SUPERIOR COURT OF (Super. Ct. No. 22HF0431) ORANGE COUNTY, OPINION Respondent;

THE PEOPLE,

Real Party in Interest.

Original proceedings; petition for a writ of mandate to challenge an order of the Superior Court of Orange County, Huy Nguyen, Judge. Petition granted in part and denied in part. The Gilliland Firm and Douglas S. Gilliland; Christine Martin Law and Christine R. Martin for Petitioner. No appearance for Respondent. Todd Spitzer, District Attorney, and Matthew O. Plunkett, Deputy District Attorney, for Real Party in Interest. * * * After the trial court denied his motion for pretrial mental health diversion pursuant to Penal Code section 1001.36, and subsequently denied him relief from the resulting order, defendant Joel Praneet Siam filed a petition in this court seeking a writ of mandate directing the trial court to grant his motion or provide other appropriate relief. 1 He argues the trial court erred in concluding he does not meet two diversion suitability criteria, one concerning whether the symptoms of his diagnosed mental health disorders would respond to treatment, and the other concerning whether he will pose an unreasonable risk of danger to public safety if treated in the community. We agree. Regarding responsiveness to treatment, the court applied the wrong legal standard when it effectively overrode the opinion of the only qualified mental health expert who weighed in on the issue. As for risk of danger, the court relied on various factual findings which are not supported by substantial evidence, and the remaining evidence is insufficient as a matter of law to support the court’s conclusion. Because the court did not make findings concerning the two remaining suitability criteria, and expressly did not determine whether to exercise its residual discretion to deny diversion even if Siam was found to be eligible and suitable, we issue a writ of mandate directing the court to vacate its order denying mental health

1 All further statutory references are to the Penal Code unless

otherwise indicated.

2 diversion and hold further proceedings to reconsider the motion consistent with section 1001.36 and this opinion. FACTS Facts relevant to the petition before us concern two separate incidents, each of which resulted in the filing of criminal charges against Siam. The first incident occurred in San Diego in August 2020 (San Diego offense). The second incident, from which this case stems, occurred in Newport Beach in March 2022 (current offense). The following sets forth the relevant factual and procedural background related to each offense. I. SAN DIEGO OFFENSE A. Circumstances of the August 2020 San Diego Offense 2 In the early morning hours of August 5, 2020, San Diego Harbor Police received a call from a taxi driver who reported a man who was his passenger, later identified as Siam, struck him three or four times in the back of the head with a skateboard and then fled by jumping out of the moving taxi. A little more than ten minutes later, police received a call from a hotel indicating a man matching the description given by the taxi driver was screaming and pressing the fire alarm in an elevator. When officers arrived at the hotel, they found Siam naked, laying on his stomach inside the elevator with his eyes closed and hands behind his back. He was “sweating profusely” and “yelling unintelligible phrases.” While being transported for medical evaluation, Siam spontaneously told the paramedic “he hit the cab

2 The facts we recite are taken from a police report concerning the

August 2020 incident which was presented to the trial court for consideration in making a decision on Siam’s diversion motion in the present case.

3 driver in the head with his skateboard, jumped out of the moving vehicle, jumped off a bridge at the airport, and ran across the street.” He also said “he took off his clothes in the elevator because people told him to and that he had breathed in meth particles in the air.” B. July 2021 Evaluation by Dr. Robert Kelin On July 29, 2021, Siam was evaluated by Dr. Robert Kelin, a licensed psychologist. A report written by Dr. Kelin, dated the same day, detailed the evaluation process, Siam’s background and answers to questions about various topics, as well as Dr. Kelin’s observations, interpretation of test result findings, diagnoses, opinions, and recommendations. Siam self-reported he “never” had problems with anger throughout his life and had never been in a fight or engaged in aggressive behavior. He believed the San Diego offense stemmed from either the paranoid thoughts he had been having that day or someone “spiking” the drinks or food he had earlier that day. In describing what took place, he said “he had very little recollection of the incident, as that day everything was blurry.” But, he recalled eating some food while waiting at a hotel where he rented a room for his father and him to stay. He was not feeling good, so he went to sleep. When he awoke, “he felt strange and may have been hallucinating.” Dr. Kelin diagnosed Siam with paranoid schizophrenia and noted it was “in partial remission with medication.” He also indicated he wanted to rule out two additional diagnoses: bipolar disorder with psychotic features and alcohol use disorder. In interpreting findings, Dr. Kelin explained the testing “did not find Mr. Siam to be a violent or aggressive individual,” “there were no stories that were violent,” “there were no violent or explosive percepts,” and “there were no indications of aggressiveness.” As a result, he

4 opined Siam’s “aggressive behavior in the [San Diego] offense reflected his paranoid thoughts.” He further opined the offense stemmed from “a paranoid break, where [Siam] was fearful and delusional,” “was experiencing paranoid thoughts[,] and was unable to maintain proper behavior.” Although he did not view Siam as cured, Dr. Kelin believed that at the time of the evaluation he was “functioning appropriately” as a result of psychotropic medication. In discussing recommended future treatment, Dr. Kelin emphasized the need for Siam “to stay on his psychotropic medication,” as well as participate in regular therapy. Regarding the latter, he explained therapy would assist by ensuring medication would continue to help Siam, and if he were to have any “changes in his mental health, his psychotropic medication could be adjusted.” Dr. Kelin also recommended Alcoholics Anonymous participation and periodic drug testing, both to determine whether Siam needed treatment in those areas. C. Mental Health Diversion Siam was charged in San Diego County with felony assault with a deadly weapon (§ 245, subd. (a)(1)). He filed a motion for mental health diversion under section 1001.36, supported, in part, by Dr. Kelin’s report. The prosecution indicated it was not opposed to Siam’s request. In mid-October 2021, the trial court granted diversion, subject to, among other conditions, compliance with treatment and monthly treatment updates to the court. After the March 2022 current offense giving rise to the charges in this case, the trial court in San Diego County revoked Siam’s mental health diversion and reinstated criminal proceedings.

5 II. CURRENT OFFENSE A. Circumstances of the March 2022 Current Offense 3 Around 9:20 a.m. on March 10, 2022, City of Newport Beach police received a phone call from employees of a car dealer who reported a man, later identified as Siam, entered their showroom, caused damage to a Rolls Royce, and then fled. When officers arrived on the scene, an employee explained Siam entered the showroom barefoot and said he wanted to buy a car with cash. He was fidgety and acting erratic.

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Siam v. Superior Court, Counsel Stack Legal Research, https://law.counselstack.com/opinion/siam-v-superior-court-calctapp-2026.