Andrew Wellisch, JD
Staff Attorney
The Therapist
March/April 2015

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Therapists have been dancing for years. For instance, the “Tarasoff Two-Step” has helped and continues to help therapists move when they hear “the music of a dangerous patient.” ¹ But, what is another type of dance you may want to be familiar with when you hear that dangerous patient tune with a cadence of a foreseeable harm? Consider a dance known as the 5150 Foxtrot. This article will discuss the steps for therapists seeking a 72-hour involuntary detention for a patient who is a danger to self or others as a result of a mental health disorder. This article will also explore frequently asked questions about this topic. Before doing so, let’s discuss the applicable state law, the Lanterman-Petris- Short Act (“LPS Act”).

The LPS Act
The LPS Act includes California Welfare and Institutions Code Section 5150 (“Section 5150”). Section 5150 attempts to harmonize the preservation of an individual’s civil liberties with the protection of public safety. This law allows for up to a 72-hour involuntary detention of a person who is a danger to others, or to himself or herself, or is gravely disabled as a result of a mental health disorder based upon probable cause. ² Since some therapists may be exploring the contours of Section 5150 for the first time, it is important to discuss a case entitled Heater v. Southwood Psychiatric Center (1996) 42 Cal. App. 4th 1068 for context.

In 1991, Robert Heater (“Heater”) asked for help after learning about the murder of his brother. He met with an intake counselor, Brent Bowers (“Bowers”), at the Southwood Psychiatric Facility (“Southwood”). Heater said to Bowers that he “wanted to get the people who murdered his brother” and “they should have the same thing done to them.”³

It was Bowers’ professional opinion that Heater qualified for a 72-hour detention under Section 5150. Because Bowers wa not an eligible professional to write a 5150 application, Bowers communicated with Southwood’s Medical Director, Ari Albala, M.D. (“Dr. Albala”). Dr. Albala arranged for an authorized staff member, Nurse Johnnie Reuben (“Reuben”) to assess and evaluate Heater to see if he should be admitted to Southwood.

After evaluating Heater, Reuben determined that Heater met the criteria for a 72-hour detention. On an application for a 72-hour detention, Reuben pointed to the following facts: the strong alcohol odor on Heater’s breath; statements from his parents that Heater had depression due to the loss of his brother; and Heater’s profanity, threats, and his extreme agitated state. Reuben admitted Heater into Southwood for an involuntary detention due to, in part, his danger to others. Reuben provided Heater with advisements for detainment.

A commissioner later released Heater from Southwood. In 1992, Heater sued Southwood and other defendants for false imprisonment and medical malpractice. A trial court found sufficient probable cause and immunity for the involuntary detention of Heater. A California Court of Appeal affirmed a trial court’s determination on these issues and stated the legal standard for probable cause:

[Probable cause refers to]…a state of facts [that] must be known to the peace officer (or authorized person) that would lead a person of ordinary care and prudence to believe, or to entertain a strong suspicion, that the person detained is mentally disordered and is a danger to himself or herself [or others] or is gravely disabled...

In order to ensure that probable cause exists to involuntarily detain a patient under Section 5150, a therapist must be able to cite to “specific and articulable facts” along with “rational inferences from those facts.” ⁴ If there is probable cause for a 72-hour detention, then an eligible professional may be able to tap into an immunity by following these steps: first, the “assessment and evaluation” step; second, the “finding of a dance partner (eligible professional)” step; and third, the “application” step.

Steps For The 5150 Foxtrot

Step 1: Assessment and Evaluation for Danger to Self or Others as a Result of a Mental Health Disorder

It is important to be cognizant of your county’s interpretation of the LPS Act since, as of the date of publication for this article, each county retains some discretion to interpret provisions of the LPS Act. While assessing and evaluating your patient to determine whether he or she should be detained under Section 5150, you want to be ready to move your feet with the tempo of the music by being knowledgeable about the law (and your county’s interpretation of it) so that you can identify facts to determine if a person is a danger to self or others as a result of a mental health disorder.

“Assessment” is “…the determination of whether a person shall be evaluated and treated pursuant to Section 5150.” ⁵ How do you make such a determination? First, you will want to consider all of your encounters with a client and his or her family since such interactions may reveal salient information. Second, you will want to evaluate the facts. In other words, you will want to analyze your client’s medical, psychological, educational, social, financial, and legal conditions. The evaluation must be “…face-to-face…” which may include telehealth.

Mental Health Disorder
What is a “mental health disorder?” Although the LPS Act does not define that term, the Diagnostic and Statistical Manual of Mental Disorders (DSM) may be helpful for the identification of symptomology of a mental health disorder. You do not necessarily need to render a clinical diagnosis of a mental health disorder for a detention under Section 5150 according to, at least, two counties in California. ⁶ A person’s mere refusal to accept treatment alone, without other facts giving rise to a mental health disorder, would likely not constitute probable cause for a mental health disorder. ⁷ A detention under Section 5150 is inappropriate if a person does not have a mental health disorder even if they are a danger to self or others. ⁸

Danger to Self
What is a “danger to self?” Although the LPS Act does not define that term, one county has interpreted danger to self as “…threats or actions indicating the intent to commit suicide or inflict serious bodily harm on oneself, or actions which place the person in serious physical jeopardy, if these actions are due to a mental [health] disorder.” ⁹ Another county has interpreted danger to self as one that is “…a deliberate intention to injure oneself (e.g., overdose) or a disregard of personal safety to the point where injury is imminent (e.g., wandering about in heavy traffic).” ¹⁰ One other county has pointed to a non-exclusive list of examples for danger to self:

1. Intentional acts of self-harm;
2. Statements of intent or plan for self-harm;
3. Behaviors that place a person in harm’s way;
4. Symptoms that increase the likelihood of dangerousness; or
5. In some circumstances, the refusal of medical treatment or care due to a mental [health] disorder (however, involuntary detentions under LPS may not be used to authorize non-psychiatric medical treatment). ¹¹

Danger to Others
What is a “danger to others?” Although the LPS Act does not define that term, one county has interpreted danger to others as “…words or actions indicating a serious intent to cause bodily harm to another person due to a mental [health] disorder.” ¹² Another county has interpreted danger to others as one that”…should be based on words or actions that indicate the person in question either intends to cause harm to a particular individual or intends to engage in dangerous acts with gross disregard for the safety of others.” ¹³ One other county has highlighted that there is “ no legal requirement for intent in order to find probable cause that a person is danger to others…”¹⁴ One county has provided a nonexclusive list of examples for danger to others:

1. Intentional acts of harm to others;
2. Statements of intent or plan for harm to others;
3. Behaviors that are dangerous to others; or
4. Symptoms that create the likelihood of dangerousness. ¹⁵

When you are assessing for danger to self or others, you will want to consider, among other items, your patient’s actions and words. “It is a good idea to thoroughly assess whether there are sufficient facts for probable cause for dangerousness even if a person’s tone appears, at first glance, to reveal joking about harm to another,” stated Linda Boyd, R.N., B.S.N., M.N., the Program Manager for the Emergency Outreach Bureau of the Los Angeles County Department of Mental Health. ¹⁶

Does the law expressly require imminent danger to self or others? “There is no express requirement of such imminence for danger to self or others,” stated Mike Phillips, Esq., the Director of Patient Advocacy for Jewish Family Service of San Diego. ¹⁷ Nonetheless, the imminence factor is an important consideration. ¹⁸ In other words, although Section 5150 does not expressly state “imminent” before “…danger to others, or to himself or herself,” it is possible that some counties may interpret this provision of law as one which requires imminent danger. ¹⁹ For example, in one county, facts giving rise to danger to self “…must be…immediate…”²⁰ By contrast, in another county, there may not be a requirement of imminence for danger to self or others. As a result, it is important to check with your local county to determine if imminence is required for danger to self or others.

Nexus
What is the meaning of “as a result of ” in Section 5150? This clause is the nexus element. If the danger to self or others occurs because of a link to the mental health disorder, then that nexus element is likely satisfied. By contrast, if a person is a danger to self or others for reasons unrelated to the mental health disorder, then an involuntary detention would likely not be permissible. Let’s consider a scenario to explore these principles.

Scenario
Suppose, during session, your patient tells you that he is going to kill “the dude” three months from now since, according to your patient, the dude slept with his wife. ²¹ In reality, however, your patient does not have a wife. He has neve been married. You have diagnosed your patient with schizophrenia. Your patient adds that he will “make history” by killing the dude and that he just recently purchased a new pistol. Your patient’s inflection and tone indicates that he is serious. Your patient explains to you that the dude lives in Beverly Hills, California, just like your patient. Although you inquire as to the dude’s specific address, your patient does not tell you that information.

Although the intended victim’s full name and specific address is not identified to you by your patient, he is identifiable to the patient, and he actually exists in Beverly Hills. If you believe that your patient’s threat is serious and credible in light of the close proximity of your patient to the potential victim, plus the serious tone and words of your patient (e.g., he will “make history”), your patient’s purchase of a gun, and the expressed motivation for the killing (e.g., “the dude slept with his [patient’s] wife”), then you arguably have identified sufficient facts to constitute probable cause for danger to others. ²²

Is there a nexus between the facts giving rise to a danger to others and a mental health disorder in this scenario? Yes. Here, your patient’s delusions that the dude slept with his wife connect the danger to the dude with the patient’s mental health disorder. One main reason for the danger is your patient’s flawed perceptions of reality, which is arguably due to his mental health disorder.

Remember, it is about having sufficient facts to satisfy the legal standard. Think back to that case entitled Heater v. Southwood Psychiatric Center, supra. In that case, Heater’s threats were important. Reuben highlighted Heater’s threats and Heater’s parents’ statements that Heater had depression due to the death of his brother. One takeaway from that case is Reuben met the criteria for probable cause even though Reuben did not specifically know when Heater would carry out the threats. Another lesson from that case is that the words of a patient and his or her family are important for your assessment and evaluation.

Although probable cause does not necessarily require a consideration of all risk factors for violence, it may be helpful to consult the body of research concerning risk factors for violence since these factors often relate to not only the words of the patient, but also the patient’s actions, character, and reputation. For instance, among other factors, the inability to control anger and history of violence are risk factors for violence. ²³ If past violence occurred recently, then it may be entitled to greater weight. ²⁴ The Historical, Clinical and Risk Management-20 (HCR 20) also points to a consideration of factors such as impulsivity and lack of personal support. ²⁵ If a person has a severe mental disorder with comorbidity of substance related disorders, then they are at a higher risk of violence than other people. ²⁶ You may also want to assess for the following factors: ideation, intent, lethality, plan, means, and protective factors. ²⁷

An assessment and evaluation of the facts involve your ability to identify words, behaviors, and other salient facts to see if they fit within the key legal terms to constitute probable cause. Additionally, your recordkeeping of any facts or absence of facts related to the below-mentioned checklist of elements is important. ²⁸ Your records may help to insulate you from legal violations by showing your good judgment and rationale for your decision to either pursue or not pursue a 5150 application. Below is a checklist of elements for Step 1 of the 5150 Foxtrot:

• Mental Health Disorder: What facts show that your patient has a mental health disorder?
• Danger to Self or Others: What facts point to your patient as a danger to self or others?
• Nexus: What facts link your patient’s danger to self or others due to a mental health disorder?

If you do not have sufficient specific and articulable facts to constitute probable cause that your patient is a danger to self or others as a result of a mental health disorder, then you want to stay proactive and continually monitor, assess, and evaluate for dangerousness as a result of a mental health disorder. If you have specific and articulable facts for these elements above, let’s move to

Step 2 of the 5150 Foxtrot.
Step 2: Finding a Dance Partner/ Eligible Professional for Writing a 5150 Application

If, after assessing and evaluating a patient you have determined that your patient presents a danger to self or others due to a mental health disorder, it is, at the outset, important to determine whether you are an eligible professional with authority to write an application for a 72-hour detention for evaluation and treatment. The 5150 application may be written by the following eligible professionals: peace officer, professional person in charge of the facility designated by the county for evaluation and treatment, member of the attending staff, or professional person designated by the county. ²⁹

Since each county may have different interpretations of provisions in the LPS Act as well as different procedures for approval of county designation, you will want to check with your local county to ensure that you are an eligible professional to write the 5150 application. If you are not an eligible professional to write the 5150 application in your county, you will want to find an eligible professional by contacting either law enforcement or the appropriate personnel. In so doing, you can coordinate efforts to have an authorized professional (e.g., sworn peace officer or a county designated professional) assess, evaluate, and ultimately, write the 5150 application.

Step 3: Writing a 5150 Application for a Patient who is a Danger to Self or Others as a Result of a Mental Health Disorder

If you are an eligible professional to write the 5150 application in your county, then it is important to consider the contents of your written application. It must state the following information: (1) the circumstances under which the person’s condition was called to the attention of the eligible professional for evaluation and treatment, and (2) the basis for probable cause to believe that the person is a danger to self or others as a result of a mental health disorder. The latter category should reflect your awareness of facts about mental health disorder, danger to self or others, and the nexus between these concepts as discussed in Step 1 of the 5150 Foxtrot.

Frequently Asked Questions Regarding The LPS Act

What is the process after an application for a 72-hour detention under Section 5150 has been written?

Before a person is admitted into a facility for a 72-hour detention, a professional person in charge of the facility or his or her designee must assess the person to determine the appropriateness of the involuntary detention.30 After such assessment and evaluation, a person may be admitted into a facility depending on the facts. If a facility designated by the county for evaluation and treatment admits that person, then the time period for evaluation and treatment cannot exceed 72 hours.

Can a person subject to a 72-hour detention under Section 5150 have an early release? Yes, it is possible. For instance, in the situation where the psychiatrist directly responsible for the person’s treatment believes, as a result of the psychiatrist’s personal observations, that the person no longer requires evaluation or treatment, then an early release may be permissible. ³¹

If there is no early release of a person, then what happens to that person at the end of the 72-hour detention?

It depends on the facts, but some persons may end up in a 14-day hold. ³² It is possible that, at the end of a 72-hour detention, a person is released, referred for additional care and treatment on a voluntary basis, or certified for intensive treatment, or there may be the appointment of a conservator or temporary conservator.

Will it be a breach of confidentiality if I contact law enforcement in my effort to find a sworn peace officer who can write a 5150 Application?

It depends on whether the disclosure was required or permitted by applicable state or federal law. Generally, a therapist’s failure to maintain confidentiality is unprofessional conduct unless there is an exception to confidentiality, which is required or permitted under the law.

For instance, under California Civil Code Section 56.10(c)(19), a psychotherapist may disclose confidential information about the client if the psychotherapist “…in good faith, believes the disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a reasonably foreseeable victim or victims, and the disclosure is made to a person or persons reasonably able to prevent or lessen the threat, including the target of the threat.” In some situations, under California Civil Code Section 56.10(c) (19), it may not be a breach of confidentiality for a psychotherapist to contact local law enforcement or a response center. Therefore if a therapist, in good faith, believes a patient must be detained under Section 5150, the therapist may disclose confidential information if all conditions are met in this section of the law and there is no conflict with other provisions of federal and/or state law.

I want to become an eligible professional for writing a 5150 application. What is the process for designation for some counties in California? Because each county may have different procedures for designation, it is advisable to consult with your local county. Below please find designation procedures for the following counties: Los Angeles County, San Diego County, and San Francisco County.

In Los Angeles County, some professionals are eligible for designation including: psychiatrists, psychologists, licensed clinical social workers, licensed marriage and family therapists, licensed psychiatric technicians, and registered nurses. ³³ In order to write the 5150 application, an eligible professional must generally be approved for designation. An eligible professional can be approved for designation by the Los Angeles County Department of Mental Health to write the 5150 application if they are sent at the direction of a Los Angeles designated hospital, to take the Los Angeles County Department of Mental Health LPS training and if the eligible professional passes the corresponding examination. ³⁴ After becoming designated by the Los Angeles County Department of Mental Health, that professional will be able to write such applications only for that Los Angeles County designated hospital, which previously sent that professional to take the LPS training and exam. ³⁵ Additionally, staff members who work for the Los Angeles County Department of Mental Health and contract agencies are eligible to write 5150 applications after they have taken the requisite training and passed the exam.

In San Diego County, some professionals are eligible for designation including: licensed psychologists, licensed clinical social workers, licensed marriage and family therapists serving as a member of the attending staff of an LPS-designated facility, and licensed clinicians serving as a member of a Psychiatric Emergency Response Team (PERT). ³⁶ Even if a professional is eligible for such designation, he or she still must study the Training Packet for Involuntary Psychiatric Detainment under Section 5150, pass an examination, and apply for and receive approval of designation from the Local Mental Health Director or his or her designee. If a person is granted designation, then they are only authorized to write an application for a 72-hour detention for evaluation and treatment while performing their job at a specific site. If a person is employed at multiple sites or programs, then he or she will need to obtain designation for each program and site.

In San Francisco County, some professionals are eligible for designation including: licensed physicians who work in a hospital medical emergency department, and licensed mental health professionals who work in a designated facility or authorized mental health facilities or authorized non-mental health facilities (e.g., primary care, substance abuse facilities). ³⁷ Even if a professional is eligible for such designation, he or she must have obtained training on involuntary psychiatric detention within the last 5 years and passed the examination. Additionally, other eligible professions for designation include licensed waivered or non-licensed professionals who work in authorized mental health facility who have, within the last 3 years, procured training and passed the examination.

I am not an eligible professional for writing a 5150 application, but I feel like my patient is a danger to self or others due to a mental health disorder. What are my options as they relate to Section 5150?

Since each county may have different options it is advisable to consult with your local county. Below please find options for therapists who are not eligible professionals for writing a 5150 application who are located in the following counties: Los Angeles County, San Diego County, and San Francisco County.

In Los Angeles County, you have, at a minimum, three options: (1) contact law enforcement by dialing 911 to see if they can send out a sworn peace officer and/or mental health peace officer response team to write the 5150 application; or (2) coordinate with a county designated hospital to see if an eligible professional there can write the 5150 application after assessing and evaluating your patient; or (3) contact the county’s mobile response team to see if they can send out an authorized professional to write the 5150 application. ³⁸

In San Diego County, you have, at least, two options: (1) contact law enforcement by dialing 911 to see if they can send out a sworn peace officer or coordinate with the Psychiatric Emergency Response Team (PERT) to write the 5150 application; or (2) coordinate with an eligible professional (i.e., licensed marriage and family therapist who is designated in San Diego County) to write the 5150 application as a member of the attending staff of an LPSdesignated facility. ³⁹

In San Francisco County, you have, at least, three options: (1) contact law enforcement by dialing 911 to see if they can send out a sworn peace officer to write the 5150 application; or (2) if there is a need for a psychiatric crisis evaluation of a person under the age of 18 years of age, contact the Child Crisis Team; or (3) if there is a need for a psychiatric crisis evaluation of a person 18 years of age or older, contact the Mobile Crisis Team. ⁴⁰

What is a phone number which may help me find a dance partner (i.e., eligible professional who can write a 5150 application) for some counties in California?

It is advisable for you to, at a minimum, check each year to ensure that you have the most current phone numbers for your county. As always, it is advisable to contact 911 for emergencies, especially since a sworn peace officer is an eligible professional for writing a 5150 application.

Conclusion
If you are faced with a dangerous patient, one way to avoid stumbling on the dance floor is to exercise good judgment by following the step for the 5150 Foxtrot. The key to exercising good judgment is diligently preparing for the patient who presents danger to self or others due to a mental health disorder. The key to diligently preparing for such a patient is understanding the law, seeking legal and clinical consultations, and reaching out to your local county resources.

This article is offered for educational purposes only and should not be used as a substitute for independent legal advice or consultation. It is not intended to address every situation that could potentially arise. Please be aware that laws, regulations, and technical standards change over time. As a result, it is important to verify and update any reference or information in this article.

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Andrew Wellisch, JD, is a staff attorney at CAMFT. Andrew is available to answer member calls regarding legal, ethical, and licensure issues.

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Endnotes

¹ See David Jensen, JD, “The Tarasoff Two-Step,” The Therapist, September/October 2012.
²See California and Welfare and Institutions Code Section 5150(a).
³ Heater v. Southwood Psychiatric Center, supra, at 1072.
⁴ People v. Triplett (1983) 144 Cal. App. 3d 283, 288.
⁵See California Welfare and Institutions Code Section 5150.4.
⁶See 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Sciences, September 2014 at 15; see also Training Packet for Involuntary Psychiatric Detainment Under Welfare and Institutions Code Section 5150, County of San Diego Health and Human Services Agency, Behavioral Health Services, March 2014 at 7.
⁷See also Mental Health Law, A Handbook on Law Governing Mental Health Treatment (7th Ed.), California Hospital Association, August 2013 at 3.3.
⁸ See 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Health Services, September 2014 at 15.
⁹See Kathleen Piche’ and John Snibbe, LPS Training Manual, Los Angeles County Department of Mental Health at 13.
¹⁰ See 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Health Services, September 2014 at 16.
¹¹ See Training Packet for Involuntary Psychiatric Detainment Under Welfare and Institutions Code Section 5150, County of San Diego Health and Human Services Agency, Behavioral Health Services, March 2014 at 7.
¹² See Kathleen Piche’ and John Snibbe, LPS Training Manual, Los Angeles County Department of Mental Health at 13.
¹³ See 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Health Services, September 2014 at 16.
¹⁴See Training Packet for Involuntary Psychiatric Detainment Under Welfare and Institutions Code Section 5150, County of San Diego Health and Human Services Agency, Behavioral Health Services, March 2014 at 8.
¹⁵Id.
¹⁶ Interview with Linda Boyd, R.N., B.S.N., M.N., the Program Manager for the Emergency Outreach Bureau of the Los Angeles County Department of Mental Health on December 27, 2014.
¹⁷Interview with Mike Phillips, Esq., the Director of Patient Advocacy for the Jewish Family Service of San Diego on December 4, 2014.
¹⁸ Id.
¹⁹See California Welfare and Institutions Code Section 5150(a).
²⁰ See 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Health Services, September 2014 at 16.
²¹The Big Lebowski (Polygram Filmed Entertainment & Working Title Films 1998).
²² The close proximity principle was obtained from an interview with Linda Boyd, R.N., B.S.N., M.N., the Program Manager for the Emergency Outreach Bureau of the Los Angeles County Department of Mental Health on November 7, 2014.
²³ Robert I. Simon, M.D., Psychiatry and Law for Clinicians, American Psychiatric Publishing, Inc. 2001, at 190.
^{24/sup> See Training Packet for Involuntary Psychiatric Detainment Under Welfare and Institutions Code Section 5150, County of San Diego Health and Human Services Agency, Behavioral Health Services, March 2014 at 8.
25 Leslie Wong, M.D., Andrew Morgan, M.D., Treena Wilkie, BScH, M.D., FRCPC, Howard Barbaree, PhD, CPsych, “Quality of Resident Violence Risk Assessments in Psychiatric Emergency Settings,” The Canadian Journal of Psychiatry, Vol. 57, No. 6, June 2012 at 375 and 377.
26 Renee L. Binder and Dale E. McNiel, “Some Issues in Psychiatry, Psychology and the Law,” Hastings Law Journal Symposium, 59 Hastings L.J. 1191, 1200 (2008); see also Seena Fazel and Martin Grann, “The Population Impact of Severe Mental Illness on Violent Crime,” 163 Amer. J. Psychiatry, 1397, 1401 (2006).
27 For a detailed discussion of these factors, see 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Health Services, September 2014 at 22.
28 Interview with Linda Boyd, R.N., B.S.N., M.N., the Program Manager for the Emergency Outreach Bureau of the Los Angeles County Department of Mental Health on December 28, 2014.
29 See California Welfare and Institutions Code Section 5150(d).
30See California Welfare and Institutions Code Section 5151.
31 California Welfare and Institutions Code Section 5152(a); see also Coburn v. Sievert (2005) 133 Cal. App. 4th 1483, 1505-1506.
32 Interview with Mike Phillips, Esq., the Director of Patient Advocacy for the Jewish Family Service of San Diego on December 10, 2014.
33 Interview with Linda Boyd, R.N., B.S.N., M.N., the Program Manager for the Emergency Outreach Bureau of the Los Angeles County Department of Mental Health on December 28, 2014.
34 See Kathleen Piche’ and John Snibbe, LPS Training Manual, Los Angeles County Department of Mental Health at 6.
35Interview with Linda Boyd, R.N., B.S.N., M.N., the Program Manager for the Emergency Outreach Bureau of the Los Angeles County Department of Mental Health on November 25, 2014.
36This is not an exhaustive list of eligible professionals for designation as declared by the San Diego County Board of Supervisors in its Resolution dated December 5, 2005. For more information on the entire list, see Training Packet for Involuntary Psychiatric Detainment Under Welfare and Institutions Code Section 5150, County of San Diego Health and Human Services Agency, Behavioral Health Services, March 2014 at 4 and 20-21.
37 See County of San Francisco Community Behavioral Health Services Policies and Procedures dated November 9, 2010 entitled, “Substantive Revision: Replaces Manual Number 3.07-02 of August 3, 2010,” which is located at 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Health Services, September 2014 at 49-52.
38 Interview with Linda Boyd, R.N., B.S.N., M.N., the Program Manager for the Emergency Outreach Bureau of the Los Angeles County Department of Mental Health on November 25, 2014.
39 Interview with Michael Phillips, Esq., Director of Patient Advocacy for Jewish Family Service of San Diego on December 4, 2014.
40See 5150/5585 Involuntary Detention Manual, San Francisco Department of Public Health, Community Behavioral Health Services, September 2014 at 2.}