{"id":104,"date":"2026-03-05T12:00:00","date_gmt":"2026-03-05T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=104"},"modified":"2026-03-05T12:00:00","modified_gmt":"2026-03-05T12:00:00","slug":"people-v-superior-court-taylor-mental-health-diversion-treatment-compliance","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=104","title":{"rendered":"People v. Superior Court (Taylor) \u2014 Mental health diversion requires evidence the defendant will actually comply with treatment, not just willingness"},"content":{"rendered":"
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Case<\/dt>\n
People v. Superior Court (Taylor)<\/dd>\n
Court<\/dt>\n
2nd District Court of Appeal<\/dd>\n
Date Decided<\/dt>\n
2026-03-05<\/dd>\n
Docket No.<\/dt>\n
B346062<\/dd>\n
Status<\/dt>\n
Reported \/ Citable<\/dd>\n
Topics<\/dt>\n
Mental health diversion, Penal Code section 1001.36, schizoaffective disorder, treatment compliance, public safety risk, hate crime, attempted murder<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

The Los Angeles County District Attorney charged Job Uriah Taylor with attempted murder, three counts of assault with a deadly weapon, and several hate crime enhancements. The charges arose from a 2023 morning rampage in Santa Monica during which Taylor allegedly attacked Black victims with a metal pipe while shouting racial slurs. One victim suffered life-altering injuries. Taylor was 25 years old at the time and had a long history of mental health issues dating to early adolescence.<\/p>\n

Taylor moved for pretrial mental health diversion under Penal Code section 1001.36, supported by a psychological evaluation from Dr. Robin Rhodes Campbell. Dr. Campbell diagnosed Taylor with a treatable schizoaffective disorder and concluded that he would not pose an unreasonable risk of danger to public safety if his psychiatric symptoms were controlled with treatment. The trial court impliedly accepted that conditional opinion and granted diversion to a community treatment facility.<\/p>\n

The People petitioned for a writ of mandate, arguing that there was no evidence Taylor would actually comply with a community-based treatment regimen and that, without compliance, he would pose an unreasonable risk of danger. The Second District Court of Appeal granted rehearing and issued this opinion.<\/p>\n

The Court’s Holding<\/h2>\n

The Second District Court of Appeal, Division One, granted the writ and directed the trial court to deny diversion. The court held that the public safety prong of section 1001.36, which requires a finding that the defendant will not pose an unreasonable risk of danger to public safety “if treated in the community,” necessarily incorporates a question about whether the defendant will follow through on treatment. A purely conditional expert opinion, framed in terms of what would happen if symptoms were controlled, does not by itself answer the statutory question.<\/p>\n

The court explained that section 1001.36 reflects a strong legislative preference for community-based mental health treatment for eligible defendants, and trial courts should not lightly deny diversion based on speculation about future noncompliance. But where the record shows actual evidence of past noncompliance, the trial court must take that into account. Here, Taylor had a history of leaving inpatient facilities without completing treatment, including a hospitalization shortly before the alleged attacks, after which he stopped taking his medications. The current charges occurred in that window of nontreatment.<\/p>\n

Given that history, the trial court could not satisfy itself that Taylor would adhere to a voluntary community treatment regimen. Without that finding, the public safety prong was not met, and the order granting diversion was an abuse of discretion. The court distinguished its analysis from People v. Cabalar, which warned against denying diversion based on conditional expert opinions in the absence of any evidence of prior noncompliance, while making clear that prior noncompliance changes the analysis.<\/p>\n

Key Takeaways<\/h2>\n