Background
Anthony Sgaraglino was involuntarily admitted to Hillmont, the inpatient psychiatric unit at Ventura County Medical Center, under Welfare and Institutions Code section 5150 on January 6, 2023. A 5150 hold — named after the code section — allows a psychiatric facility to detain a person for up to 72 hours when they pose a danger to themselves or others due to a mental health disorder. Anthony was diagnosed with bipolar disorder.
After three days, a hospital physician determined Anthony did not meet the criteria for a continued 5250 hold (which allows up to 14 additional days of intensive treatment) and discharged him. His parents, Franklin and Linda Sgaraglino, alleged they had told hospital staff that Anthony was suicidal, pleaded for his continued hospitalization, and were told he would be released without medication despite these warnings. On January 10, 2023 — one day after discharge — Anthony died by suicide.
His parents sued the County of Ventura for wrongful death, arguing the hospital negligently released Anthony without medication and against the family’s objections. The trial court granted summary judgment for the county, finding the hospital immune under Welfare and Institutions Code section 5113. The Sgaraglinos appealed, arguing that the immunity does not apply to gross negligence.
The Court’s Holding
The Second Appellate District affirmed summary judgment, holding that section 5113 of the Lanterman-Petris-Short Act (LPS Act) — California’s statute governing involuntary psychiatric commitment — immunizes a psychiatric facility from civil or criminal liability for “any action by a person released at or before the end of the period for which the person was admitted.” The court held this language plainly covers Anthony’s post-discharge suicide: the family’s claim was that the hospital’s release decision caused Anthony’s death, and that post-release harm is exactly what the statute immunizes.
The court rejected the Sgaraglinos’ argument that section 5113 contains an implicit exception for gross negligence. The statute contains no such language, and courts apply statutes as written when the language is clear and unambiguous. The court noted that the immunity is a deliberate legislative choice: the LPS Act was designed in part to end inappropriate indefinite commitments, and the Legislature recognized that some patients released after 72 hours may harm themselves or others — and made the deliberate policy choice to immunize facilities against liability for those harms.
The court also rejected theories of liability raised for the first time on appeal (including claims under 42 U.S.C. § 1983, the Bane Act, and Government Code section 815.6), holding them forfeited because they were not raised in the trial court or pleaded in the operative complaint. Expert evidence that the release fell below the standard of care was similarly unavailing: allowing negligence-standard challenges to defeat the immunity would make summary judgment on section 5113 grounds “virtually unavailable.”
Key Takeaways
- Welfare and Institutions Code section 5113 provides broad, absolute immunity to psychiatric hospitals for post-release harms after a 5150 hold — including the patient’s own suicide — with no exception for gross negligence.
- The immunity is not defeated by evidence that the hospital’s release decision fell below the medical standard of care or that family members objected to the discharge.
- Families who believe a psychiatric discharge was negligent face a nearly insurmountable barrier to recovery under California law for post-release harms; the remedy is legislative, not judicial.
- New theories of liability not raised in the trial court or pleaded in the complaint are forfeited and cannot be raised for the first time on appeal, even if the facts might support them.
- The 2026 amendments to section 5113 (effective January 1, 2026) were noted but did not affect this pre-2026 case — practitioners should review whether the amendments changed the immunity scope going forward.
Why It Matters
California’s mental health system releases thousands of involuntarily committed patients every year when the 72-hour 5150 hold expires and they do not meet criteria for further commitment. Families of patients who subsequently harm themselves or others — already grappling with grief and trauma — routinely ask whether hospitals can be held responsible. This decision reinforces that the answer is almost always no. The LPS Act’s immunity was deliberately designed to protect facilities making difficult, legally constrained discharge decisions, and that policy choice takes precedence even over compelling facts.
For healthcare providers and hospitals, the decision is a strong affirmation that section 5113 provides real protection — as long as they can show the discharge decision was made within the statutory framework. For plaintiffs’ attorneys, it underscores that post-discharge injury claims against psychiatric facilities in California face an uphill battle, and that identifying specific pre-discharge in-hospital negligence (like a medication error during the stay, rather than the discharge decision itself) may offer a better path to recovery than challenging the release decision.