A California court recently ruled that individuals facing conservatorship under the Lanterman-Petris-Short Act (LPS Act) must be informed of their right to a jury trial. This decision came in the case of K.L., who was declared gravely disabled and placed under conservatorship. The ruling highlights the importance of protecting the rights of individuals with mental health issues.
The court's decision affects individuals who may be subjected to conservatorships, which can significantly restrict their liberties. It underscores the legal requirement that proposed conservatees must be fully informed of their rights, including the right to a jury trial, before any decisions are made about their care and treatment.
Background
The case, Conservatorship of K.L. (Docket No. B351841), involved K.L., who was diagnosed with psychotic, posttraumatic, and major depressive disorders. In October 2025, the Santa Barbara County Public Guardian filed a petition to appoint a conservator for K.L., citing her inability to care for herself due to her mental health conditions.
K.L. contested the conservatorship, expressing her desire for a trial via Zoom. However, during the pretrial hearing in December 2025, her attorney did not explicitly waive her right to a jury trial, nor did they inform K.L. of her right to such a trial. The trial court also failed to advise K.L. of her right to a jury trial or secure a personal waiver from her.
Despite these oversights, the trial court proceeded with a court trial and ultimately found K.L. gravely disabled, appointing the Public Guardian as her conservator for one year. The court's ruling included restrictions on K.L.'s rights, such as prohibiting her from driving or possessing firearms.
The Ruling
The California Court of Appeal reversed the trial court's ruling, emphasizing that K.L. was not adequately informed of her right to a jury trial. The court stated, "The trial court’s failure to advise K.L. of her right to a jury trial here is reversible error." The judges involved in the decision included Justice Baltodano, Presiding Justice Cody, and Justice Yegan.
The court reiterated that individuals facing conservatorship are entitled to a unanimous jury verdict on the issue of grave disability. The ruling highlighted that a person's waiver of the right to a jury trial must be made knowingly and intelligently, and in this case, K.L. was not properly advised of her rights.
The court referenced previous rulings, including Conservatorship of Heather W., which established that trial courts must inform proposed conservatees of their right to a jury trial. The court concluded that without such advisement, K.L. could not have knowingly waived her right.
Impact
This ruling has significant implications for individuals facing conservatorship in California. It reinforces the necessity for courts to ensure that proposed conservatees are fully informed of their rights, particularly the right to a jury trial. This decision may lead to increased scrutiny of conservatorship proceedings and the procedural safeguards in place to protect the rights of individuals with mental health conditions.
Moreover, the ruling sets a precedent that could influence future conservatorship cases. It underscores the importance of due process and the need for clear communication regarding the rights of individuals who may be subject to conservatorship, ensuring that their liberties are not infringed upon without proper legal protections.
What's Next
Following this ruling, the case has been sent back to the lower court for further proceedings consistent with the appellate court's decision. It remains to be seen if the Public Guardian will seek to appeal this ruling or if there will be related cases that address similar issues regarding conservatorship rights.