When a Court Ignores Mental Health Experts: How Siam v. Superior Court (People) Strengthens Mental Health Diversion Rights in California
California’s mental health diversion law, Penal Code section 1001.36, was created to give individuals with qualifying mental health conditions an opportunity for treatment instead of incarceration. The law reflects a clear legislative preference for rehabilitation over punishment when mental illness plays a role in criminal conduct. However, as the recent case Siam v. Superior Court (People) demonstrates, trial courts do not always apply this law correctly.
At Wallin & Klarich, our experienced criminal defense attorneys closely monitor appellate decisions like this one because they directly impact how we advocate for our clients seeking mental health diversion. Call Wallin & Klarich today toll-free at (877) 466-5245 for your free consultation with one of our criminal defense attorneys near you.
What Is Mental Health Diversion Under Penal Code Section 1001.36?
Mental health diversion allows an accused individual with a qualifying mental disorder to pause criminal proceedings and enter a structured treatment program. If the program is successfully completed, the criminal charges may be dismissed.
To qualify, the court must find that:
- The individual has a qualifying mental disorder that is not excluded by statute
- The mental disorder played a significant role in the charged offense
- A qualified mental health expert believes the individual’s symptoms would respond to treatment
- The individual consents to diversion and agrees to comply with treatment
- The individual does not pose an unreasonable risk to public safety
While eligibility is often straightforward, many cases turn on the issue of suitability, particularly whether the accused individual is likely to benefit from treatment.
The Facts of Siam v. Superior Court (People)
Joel Praneet Siam was charged with multiple criminal offenses and sought mental health diversion under Penal Code section 1001.36. In support of his request, Siam underwent a comprehensive six-hour psychological evaluation conducted by licensed psychologist Dr. Lisa Grajewski.
Dr. Grajewski issued a detailed report concluding that Siam met all statutory requirements for mental health diversion. Specifically, she opined that:
- Siam suffered from qualifying mental disorders
- His mental health conditions contributed to the alleged offenses
- He would respond positively to treatment
- He consented to diversion
- He did not pose an unreasonable risk to public safety
Despite this unchallenged expert opinion, the trial court denied Siam’s request. Although the court acknowledged that Siam was eligible for diversion, it found him unsuitable, concluding—contrary to the psychologist’s opinion—that he would not respond to treatment. The court relied on prior instances where Siam refused medication and the fact that he had previously participated in mental health diversion.
Siam then filed a petition for writ of mandate, asking the appellate court to intervene.
The Appellate Court’s Ruling: Expert Opinions Matter
The Court of Appeal granted Siam’s petition in part and issued a critical clarification of the law.
The appellate court emphasized that Penal Code section 1001.36 requires the determination of treatment responsiveness to be based on the opinion of a qualified mental health expert, such as a psychologist or psychiatrist. In Siam’s case:
- A licensed psychologist expressly opined that his symptoms would respond to treatment
- There was no competing expert opinion
- The prosecution did not challenge the psychologist’s qualifications
- The trial court identified no flaw in the reasoning or basis of the expert’s conclusions
By substituting its own judgment for that of a qualified mental health expert, the trial court applied the wrong legal standard. The appellate court held that this constituted an abuse of discretion, reinforcing that courts cannot simply disregard expert opinions without a legally valid reason.
Why This Case Matters for Mental Health Diversion Cases
Siam v. Superior Court (People) sends a strong message: trial courts must follow the statutory framework established by the Legislature. When a qualified mental health expert concludes that an accused individual will respond to treatment, the court cannot reject that conclusion based on speculation, personal disagreement, or unsupported assumptions.
This decision strengthens the protections built into Penal Code section 1001.36 and provides powerful authority for defense attorneys challenging improper denials of mental health diversion.
How Wallin & Klarich Can Help
Mental health diversion cases require more than simply filing a motion—they demand careful preparation, strong expert support, and a deep understanding of appellate case law. At Wallin & Klarich, our attorneys:
- Work closely with qualified mental health professionals
- Prepare comprehensive diversion motions supported by expert evaluations
- Challenge trial court errors through writs and appeals when necessary
- Aggressively advocate for treatment-focused outcomes instead of incarceration
Call Wallin & Klarich Today
If you or a loved one suffers from a mental health condition and is facing criminal charges, you may be entitled to diversion—even if a trial court initially denies it. The outcome of Siam v. Superior Court shows that wrongful denials of mental health diversion can be overturned. At Wallin & Klarich, we have been defending the rights of individuals accused of crimes for over 40 years.
At Wallin & Klarich, we have offices all over Southern California: Irvine, Pasadena, Riverside, San Bernardino, San Diego, Torrance, and Anaheim. Additionally, our law firm can handle many types of cases statewide.
Discover how our team can assist you. Contact us today, toll-free at (877) 466-5245 for a free consultation with a skilled criminal defense attorney near you.
