June 8, 2026
Court of Appeal, Second Appellate District, Division Six
The Rule of Sgaraglino v. County of Ventura is that Welfare and Institutions Code section 5113 immunizes psychiatric facilities from civil liability for any action by a patient released after involuntary detention, even when the release decision allegedly constitutes gross negligence, under circumstances where the patient was involuntarily detained under section 5150 and released at or before the end of the authorized detention period.
March 6, 2026
Court of Appeal of the State of California, Third Appellate District
The Rule of Nichols v. Alghannam is that treating a patient without valid hospital staff privileges constitutes "professional negligence" subject to the 3-year medical malpractice statute of limitations under Code of Civil Procedure section 340.5, under circumstances where the physician provided pain management services within the scope of his license but allegedly violated hospital privilege requirements.
February 18, 2026
Court of Appeal of the State of California, Third Appellate District (Yuba)
The Rule of Nichols v. Alghannam is that the MICRA statute of limitations (Code Civ.