Parker

In 2000, defendant and appellant Wenonah Karen Parker was found guilty, but not guilty by reason of insanity, of various crimes. (Pen. Code, § 1026.) Defendant was committed to Patton State Hospital (Patton). In 2011, the trial court granted defendant outpatient status. (§ 1026.2.) The outpatient agencies refused to accept defendant due to her behavior and mental condition. As a result, defendant remained hospitalized at Patton, in the inpatient program. In 2012, the trial court revoked the order granting defendant outpatient status. (§ 1608.)

Defendant raises three issues on appeal. First, defendant contends the State Department of State Hospitals and the outpatient treatment agencies acted unlawfully by refusing to admit defendant. Second, defendant asserts the controlling statutes do not authorize revocation of outpatient status for a person who was not given the opportunity to participate in an outpatient program. Third, defendant contends collateral estoppel requires defendant’s outpatient status to remain in place because there were not material changes to defendant’s condition. In defendant’s appellant’s reply brief, she also raises an issue concerning substantial…