Cody M. v. County of Sonoma CA1/5

DISCUSSION

Plaintiff seeks reversal of the trial court’s decision to deny his motion to seal the entire record of his section 8103 petition proceeding. He argues that such proceedings, which necessarily involve portions of the Lanterman-Petras-Short (LPS) Act (§ 5000 et seq.), are nonpublic special proceedings. He further argues that his constitutional right to privacy protects his mental health medical history and that the trial court erred in applying the framework under California Rules of Court, rules 2.550 and 2.551, when it denied his motion to seal the entire record. A trial court that denies a motion to seal is not required to make express factual findings. (Overstock, Inc. v. Goldman Sachs Group, Inc. (2014) 231 Cal.App.4th 471, 492 (Overstock).) “[W]e review the ultimate discretionary decision to deny sealing by inquiring whether substantial evidence supports the trial court’s express or implied findings that the requirements for sealing are not met.” (Ibid.) We defer to the trial court’s credibility determinations and consider all evidence and reasonable

3 inferences in the light most favorable to the trial court’s order. (Id. at p. 491, fn. 11.) Plaintiff argues that…