{"id":204,"date":"2026-04-21T12:00:00","date_gmt":"2026-04-21T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=204"},"modified":"2026-04-21T12:00:00","modified_gmt":"2026-04-21T12:00:00","slug":"people-v-landrine-mental-health-diversion-satisfactory-performance-section-1001-36","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=204","title":{"rendered":"People v. Landrine \u2014 Defendant Cannot “Satisfactorily Perform” Mental Health Diversion Without Substantially Complying with Diversion Requirements"},"content":{"rendered":"
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\n
Case<\/dt>\n
People v. Landrine<\/dd>\n
Court<\/dt>\n
6th District Court of Appeal<\/dd>\n
Date Decided<\/dt>\n
2026-04-21<\/dd>\n
Docket No.<\/dt>\n
H052071<\/dd>\n
Status<\/dt>\n
Reported \/ Citable<\/dd>\n
Topics<\/dt>\n
Mental health diversion; Penal Code section 1001.36; satisfactory performance; substantial compliance; multiple criminal cases; dismissal<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Keena Teloca Landrine was charged in four separate cases with a string of offenses including burglaries of hospitals, senior living facilities, and homes; identity theft; and grand theft. The crimes occurred between June 2020 and April 2021 and involved Landrine entering various premises under false pretenses (claiming to be a caregiver, security employee, maintenance worker, or other staff) and stealing cash, credit cards, identification, and personal property from employees, patients, and elderly residents.<\/p>\n

In August 2021, Landrine applied for mental health diversion under Penal Code section 1001.36. Section 1001.36 allows certain defendants with diagnosed mental disorders to participate in court-supervised mental health treatment in lieu of prosecution. If the defendant performs satisfactorily during the diversion period, the charges are dismissed. Landrine’s counsel represented that the diversion program would be intense with high expectations and that further misconduct would lead her back to face the charges.<\/p>\n

The trial court granted diversion in September 2021. While in the diversion program, however, Landrine committed several dozen new crimes. Despite these repeated violations, the trial court found that Landrine had “satisfactorily performed” because of “amazing progress” she had made after returning to custody. It dismissed the charges. The district attorney appealed.<\/p>\n

The Court’s Holding<\/h2>\n

The Sixth District Court of Appeal reversed and remanded. The court held that Penal Code section 1001.36 does not authorize trial courts to find satisfactory performance unless a defendant substantially performs the requirements imposed on diversion. Landrine’s commission of several dozen new crimes during the diversion period was not substantial performance, regardless of progress made afterward.<\/p>\n

The mental health diversion statute is structured around performance during the diversion period itself, not after. Successful completion is intended to demonstrate that the defendant’s mental health condition has been treated effectively such that the public can be confident the defendant will not reoffend. Repeated criminal violations during diversion are inconsistent with that goal and undermine the statutory premise. While trial courts have discretion in evaluating satisfactory performance, that discretion does not extend to finding satisfactory performance in the face of dozens of new offenses, even where the defendant later shows progress.<\/p>\n

The court emphasized that mental health diversion is not a guarantee of dismissal regardless of conduct. The Legislature crafted section 1001.36 with the requirement that diversion participants substantially perform the diversion requirements. Trial courts that disregard this requirement abuse their discretion and exceed their statutory authority.<\/p>\n

Key Takeaways<\/h2>\n