Julian v. Mission Community Hospital

Plaintiff, a middle school math teacher, filed suit against various defendants after she was involuntarily detained for mental health evaluation and treatment. Plaintiff alleged that school defendants did not have probable cause to detain her under Welfare and Institutions Code section 5150, that hospital defendants lacked probable cause to continue to detain her and to admit her to the hospital where she spent one night before being released, and that she was entitled to monetary damages for various alleged violations of the Lanterman-Petris-Short Act, Welfare and Institutions Code 5000 et seq., and of her civil rights. The Court of Appeals concluded that there was no private right of action for the violations of the Act plaintiff alleged; the school district and the school police were immune from liability under 42 U.S.C. 1983; the individual officers were entitled to qualified immunity; the hospital and physician were not state actors for purposes of plaintiff's section 1983 claims; most of the provisions of the California Constitution plaintiff invoked did not create causes of action for damages; plaintiff failed to state a claim for violations of those provisions that might provide such a cause of action; and, because the hospital defendants were not state actors for purposes of section 1983, they cannot be liable for plaintiff's alleged violations of the California Constitution. Accordingly, the Court of Appeals affirmed the trial court's decision sustaining the hospital defendants' demurrers to plaintiff's third amended complaint and granting the school defendants' motion for summary judgment.