People v. Angel R. CA2/1, B305405

Angel R., proven developmentally disabled, was involuntarily committed under Welf. & Inst. Code § 6500; initial commitment sustained Jan. 2019 and a renewal petition was tried Feb. 25, 2020.
Trial evidence: 41 pages of partly redacted Canyon Springs records plus testimony from Dr. Bess Walsh (treating psychologist) and Dr. Kory Knapke (court‑appointed expert).
Records and testimony documented repeated provocative verbal abuse, threats, and episodes of physical aggression (including an April 24, 2019 incident where Angel charged and struck staff).
Both experts opined Angel’s intellectual disability caused impulsivity and serious difficulty controlling dangerous behavior; they both concluded less‑restrictive placement was inappropriate.
Trial court admitted Canyon Springs records under the business‑records exception over Angel’s hearsay/due‑process objections and found the § 6500 elements proven beyond a reasonable doubt, ordering recommitment for one year.
On appeal Angel argued (1) insufficient evidence that the developmental disability substantially caused his inability to control dangerous behavior and (2) erroneous admission of Canyon Springs records violated hearsay and due process; the Court of Appeal affirmed.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Angel)	Held
Sufficiency: Was the developmental disability a substantial cause of serious difficulty controlling dangerous behavior?	Expert testimony and objective facility records show intellectual disability produced impulsivity that caused dangerous conduct.	Experts failed to isolate intellectual disability from other psychiatric disorders; evidence insufficient on causation.	Affirmed. Substantial evidence (logs + expert opinions) supported causation and danger findings.
Admissibility: Were Canyon Springs records admissible as business records and sufficiently trustworthy?	Records were routine treatment/monitoring documents, not litigation‑generated, so they fit Evidence Code §1271.	Records were not routine/trustworthy and contained case‑specific hearsay and subjective conclusions.	Affirmed. Court did not abuse discretion admitting records as business records.
Due process / Hearsay impact: Did admitting portions of records violate due process or require reversal?	Even if portions were inadmissible, experts relied on independent observations and objective entries; any error was harmless.	Admission of staff case‑specific hearsay and subjective statements violated due process and prejudiced the outcome.	Affirmed. Admission, if erroneous as to some subjective passages, was harmless under either Chapman or Watson standards.

People v. Sanchez, 63 Cal.4th 665 (expert may rely on hearsay to form opinion but may not relate case‑specific hearsay as true)
People v. Sweeny, 175 Cal.App.4th 210 (elements of § 6500 commitment)
Conservatorship of S.A., 25 Cal.App.5th 438 (admission of medical/psychiatric records under business records exception and due process)
People v. Covarrubias, 1 Cal.5th 838 (standard of review for sufficiency of evidence)
Chapman v. California, 386 U.S. 18 (harmless beyond a reasonable doubt standard)
Melendez‑Diaz v. Massachusetts, 557 U.S. 305 (documents prepared for litigation are treated differently under hearsay rules)
Bullcoming v. New Mexico, 564 U.S. 647 (similar to Melendez‑Diaz on forensic reports and confrontation/hearsay concerns)
Palmer v. Hoffman, 318 U.S. 109 (reports made after an incident for litigation not routine business records)
People v. Cuevas, 213 Cal.App.4th 94 (distinguishable; emphasizes need to show intellectual disability was substantial factor)