Conservatorship of C.S. CA3

BACKGROUND

On March 13, 2025, C.S. requested a contested review hearing under section 5364 to assess whether her conservatorship should be terminated. At the hearing, C.S. called Dr. Heather O’Connell as a witness. Dr. O’Connell had recently evaluated C.S. and reviewed her medical records. Dr. O’Connell did not believe C.S. was ready for the conservatorship to terminate, even though her mental health diagnosis had changed. Dr. O’Connell opined that C.S.’s plan to provide for her basic needs such as food, clothing, and shelter was not viable. C.S. also testified. C.S. stated that she disagreed with her diagnosis and asked to go home. The trial court denied C.S.’s request under section 5364, concluding that she remained gravely disabled, was unable to care for herself, and was in the proper placement. C.S. timely appealed.

DISCUSSION

In Wende, our state Supreme Court held that, when appointed counsel in a criminal appeal submits a brief raising no specific issues or describing the appeal as frivolous, the Court of Appeal must conduct a review of the entire record. (People v. Delgadillo (2022) 14 Cal.5th 216, 221.) This procedure applies “to the first appeal as of right and is…