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Filed 9/25/24 P. v. Briggs CA1/4

NOT TO BE PUBLISHED IN OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not 

certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not 

been certified for publication or ordered published for purposes of rule 8.1115. 

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION FOUR

THE PEOPLE,

Plaintiff and Respondent,

v.

RONNIE LYNN BRIGGS,

Defendant and 

Appellant.

 A168609

 (Contra Costa County

Super. Ct. No. 04-22-

01209)

Defendant Ronnie Lynn Briggs was found incompetent to 

stand trial and committed to the Department of State Hospitals 

(the Department). The trial court determined that Briggs lacked 

the capacity to decide whether to take antipsychotic drugs, and, 

without the drugs, he would likely suffer serious harm to his 

physical or mental health. The court accordingly ordered Briggs 

to be involuntarily medicated under Penal Code1 section 1370, 

subdivision (a)(2)(B)(i)(I). Briggs argues that the court’s order is 

not supported by substantial evidence. We affirm.

BACKGROUND

After Briggs was found incompetent to stand trial and 

committed to the Department, the Department filed a petition for 

1 All statutory references are to the Penal Code.
2

an order to compel involuntary treatment of Briggs with 

antipsychotic medication under the procedures set forth in 

section 1370, subdivisions (a)(2)(C) and (a)(2)(D).2 The petition 

included the required certification from Briggs’s treating 

psychiatrist, who certified that involuntary medication was 

required and warranted under section 1370, 

subdivision (a)(2)(B)(i)(I) and (II). The petition followed an 

August 2, 2023 medication review hearing, at which an 

administrative law judge ordered that temporary involuntary 

antipsychotic medication be administered to Briggs. 

The trial court held a hearing on the Department’s petition 

and heard testimony from Briggs’s treating psychiatrist at 

Atascadero State Hospital, Dr. Joshua Deane. The court 

qualified Deane as an expert in psychiatric treatment of medical 

illness, and Deane testified that his job entailed taking care of 

patients in the units at the hospital, diagnosing their problems, 

and prescribing proper medication to improve their mental state. 

After hearing Deane’s testimony and argument from counsel, the 

court granted the petition and ordered Briggs to be involuntarily 

medicated under section 1370, subdivision (a)(2)(B)(i)(I). Briggs 

filed a timely appeal.

2 These provisions allow for the filing of a petition to obtain 

an order authorizing the involuntary treatment of a defendant 

committed to the Department with antipsychotic medication 

where the defendant previously consented to antipsychotic 

medication but later withdrew such consent or where the treating 

psychiatrist determines that antipsychotic medication has 

become medically necessary and appropriate. (§ 1370, 

subd. (a)(2)(C)–(D).)
3

DISCUSSION

Individuals have a qualified constitutional right to refuse 

antipsychotic medication under the federal and state 

constitutions. (In re Qawi (2004) 32 Cal.4th 1, 14–16.) Our 

Legislature has amended section 1370 to meet modern 

constitutional standards related to involuntary medication orders 

for defendants deemed incompetent to stand trial and committed 

to the Department. (People v. Lameed (2016) 247 Cal.App.4th 

381, 396; § 1370, subd. (a)(2).) Subdivision (a)(2)(B) permits 

involuntary medication in three circumstances. (§ 1370, 

subd. (a)(2)(B)(i)(I-III).) The trial court here made factual 

findings under the first of these provisions, which requires that: 

“[1] the defendant lacks capacity to make decisions regarding 

antipsychotic medication, [2] the defendant’s mental disorder 

requires medical treatment with antipsychotic medication, and 

[3] if the defendant’s mental disorder is not treated with 

antipsychotic medication, it is probable that serious harm to the 

physical or mental health of the defendant will result.” (§ 1370, 

subd. (a)(2)(B)(i)(I).) The question for us is whether the record 

contains substantial evidence from which the trial court could 

have found it highly probable that the requisite facts were true 

(the clear and convincing evidence standard of proof). (People v. 

Garcia (2024) 99 Cal.App.5th 1048, 1054 (Garcia).)3 It does. 

3 The parties agree that clear and convincing evidence is 

the applicable standard of proof, so we assume for purposes of 

this opinion that this standard applies. (See Garcia, supra, 

99 Cal.App.5th at p. 1054, fn. 2.)
4

Briggs disputes only the trial court’s finding of probable 

serious harm to his health. Under the statute, “Probability of 

serious harm to the physical or mental health of the defendant 

requires evidence that the defendant is presently suffering 

adverse effects to their physical or mental health, or the 

defendant has previously suffered these effects as a result of a 

mental disorder and their condition is substantially 

deteriorating. The fact that a defendant has a diagnosis of a 

mental disorder does not alone establish probability of serious 

harm to the physical or mental health of the defendant.” (§ 1370, 

subd. (a)(2)(B)(i)(I).) 

The evidence was sufficient to support the order. Deane 

opined that Briggs suffered from schizophrenia. When asked to 

describe Briggs’s “active symptoms” Deane said, “He is very 

delusional. Demonstrates disorganization, illogical thinking, 

very poor judgment.” Briggs was under the belief that he was 

sent to the hospital solely because he had difficulty with a “chief 

police” who stole Briggs’s supplemental security income. Deane 

had increased Briggs’s dose of medication a week before the 

hearing, and Briggs thereafter was able to sit down and talk with 

the doctor without displaying “any threatening behavior or 

becom[ing] agitated.” Previously, Briggs was “very loud, in a 

sense, belligerent,” and the hospital had to have a team with 

Briggs, who demanded to make many calls, including to NASA. 

After his dose increase, Briggs was able to sleep through the 

night without yelling in his room, he was “cordial enough to get 

along without the violence,” and he was less agitated, demanding, 
5

and aggressive. Briggs’s delusional beliefs nonetheless 

continued. For example, on the day of the hearing, Briggs told 

Deane that a hospital social worker’s husband was the cousin of 

the “chief police” who stole Briggs’s money and conspired to send 

Briggs to the hospital.

Deane’s testimony regarding Briggs’s behavior — his 

delusions, agitation, and belligerence — established that Briggs 

presently exhibited symptoms of a mental disorder that posed 

“adverse effects” to his mental health. (§ 1370, 

subd. (a)(2)(B)(i)(I); Garcia, supra, 99 Cal.App.5th at pp. 1055–

1056.) Briggs undisputedly suffered from paranoid delusions, 

and we agree with Garcia that accepting symptoms such as these 

as evidence of adverse effects on a defendant’s mental health does 

not violate the statutory mandate that a diagnosis of a mental 

disorder may not alone establish the requisite probability of 

serious harm to a defendant’s physical or mental health. (Garcia, 

at p. 1056, citing § 1370, subd. (a)(2)(B)(i)(I).) Deane’s testimony 

also supports findings that (1) without the increase in 

medication, Briggs had not been sleeping through the night; and 

(2) Briggs’s agitation and belligerence while not sleeping 

rendered communication with Briggs, and hence treatment, more 

difficult. Deane opined that medication is the only effective 

means to treat schizophrenia, and Briggs’s behavioral and sleep 

improvements correlated with the increase in his medication. A 

rational fact finder could thus conclude that clear and convincing 
6

evidence established that Briggs was suffering adverse effects to 

his mental health caused by his mental disorder.4

DISPOSITION

The order is affirmed.

BROWN, P. J.

WE CONCUR:

GOLDMAN, J.

DOUGLAS, J.

People v. Briggs (A168609)

4 Briggs also argues that there was insufficient evidence 

that he was a danger to others. Given our determination that 

substantial evidence supports the trial court’s finding under 

section 1370, subdivision (a)(2)(B)(i)(I), we need not address this 

additional argument.

 Judge of the Superior Court of California, County of 

Contra Costa, assigned by the Chief Justice pursuant to article 

VI, section 6 of the California Constitution.