People v. Holaday CA5, F086926

Kyle Holaday was found not guilty by reason of insanity (NGI) for one count of murder, four counts of attempted murder, and one count of animal cruelty, all with firearm enhancements.
Holaday was committed to the Department of State Hospitals (DSH) for mental health treatment with a combined term of 12 years determinate plus 115 years to life indeterminate.
In 2023, Holaday petitioned for release from DSH to enter a community-based outpatient treatment program (CONREP) under Penal Code § 1026.2, claiming restoration of sanity.
The DSH and CONREP doctors provided conflicting testimony and reports regarding Holaday's current mental health status and readiness for conditional release.
The trial court held an evidentiary hearing, considering expert opinions, Holaday's testimony, and his history, ultimately denying the petition for release.
Holaday appealed, arguing the denial was not supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Evidence on Danger to Others	Holaday would still pose a danger due to unresolved mental illness and incomplete treatment.	Holaday contended there was no substantial evidence he would be a danger if released under supervision.	Sufficient evidence supported denial; trial court discretion upheld.
Mental Disorder Justifying Commitment	Expert evidence showed ongoing PTSD and alcohol-use disorder warrant continued hospitalization.	Holaday argued PTSD was in remission and not a basis for continued commitment.	Court found PTSD and alcohol-use disorder justified continued commitment.
Weight of Expert Opinions	DSH/CONREP experts' opinions on needs for continued treatment should be credited.	Holaday and his expert (Dr. McGee) argued for outpatient readiness and criticized opposing reports.	Court credited state’s experts; defense evidence did not outweigh.
Impact of Commitment Offense/Background	Holaday's violent offense, criminal and substance use history are relevant to risk.	Holaday argued only current mental state should be reviewed, not past acts.	Court may consider both history and present mental state.

People v. Dobson, 161 Cal.App.4th 1422 (Restoration of sanity process explained; burden on applicant for release)
People v. Bartsch, 167 Cal.App.4th 896 (Appellate review of trial court's order for abuse of discretion)
People v. Sword, 29 Cal.App.4th 614 (Trial court may evaluate the validity of expert opinion when determining dangerousness)
People v. Fields, 35 Cal.3d 329 (Antisocial personality alone, absent other symptoms, cannot justify an insanity finding)