BILL ANALYSIS                                                                                                                                                                                                    �







                      SENATE COMMITTEE ON PUBLIC SAFETY
                            Senator Loni Hancock, Chair              A
                             2013-2014 Regular Session               B

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          AB 2520 (Maienschein)                                      0
          As Amended April 1, 2014 
          Hearing date:  June 24, 2014
          Penal Code
          MK:JM:mc

                           PAROLE: PRIMARY MENTAL CLINICIANS  

                                       HISTORY

          Source:  AFSCME Local 2620

          Prior Legislation: None

          Support: National Association of Social Workers, California  
                   Chapter; Legal Services for Prisoners with Children

          Opposition:California Public Defenders Association; Taxpayers  
          for Improving Public Safety

          Assembly Floor Vote:  Ayes 77 - Noes 0



                                        KEY ISSUES
           
          SHOULD AN EXPERT EVALUATOR OF AN INMATE AS A POSSIBLE MENTALLY  
          DISORDERED OFFENDER BE REQUIRED, AT THE INMATE'S REQUEST, TO CONSULT  
          WITH THE INMATE'S PRIMARY MENTAL CLINICIAN?

          SHOULD A PSYCHOLOGIST WHO PERFORMS A PSYCHOLOGICAL EVALUATION OF A  
          LIFE-TERM INMATE FOR PURPOSES OF A PAROLE CONSIDERATION HEARING, BE  
          REQUIRED, AT THE INMATE'S REQUEST, TO CONSULT WITH THE INMATE'S  




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          PRIMARY MENTAL CLINICIAN?




                                       PURPOSE

          The purpose of this bill is to 1) provide that where an inmate  
          pending release on parole is evaluated by experts to determine  
          if he or she should be treated on parole as a mentally  
          disordered offender, the evaluators shall consult with the  
          inmate's primary clinician, if the inmate so requests; and 2)  
          provide that where a psychologist performs an evaluation of an  
          inmate for purposes of parole consideration, the psychologist  
          shall consult with the inmate's primary clinician, if the inmate  
          so requests.
          
           Existing law  states a legislative finding and declaration that  
          the Department of Corrections (CDCR) should evaluate each  
          prisoner for severe mental disorders during the first year of  
          the prisoner's sentence, and that severely mentally disordered  
          prisoners should be provided with an appropriate level of mental  
          health treatment while in prison and when returned to the  
          community.  (Pen. Code � 2960.) 

           Existing law  requires, as a condition of parole, a prisoner who  
          meets the following criteria to be treated by the State  
          Department of State Hospitals (DSH) and DHS to provide the  
          necessary treatment: 

                 The prisoner has a severe mental disorder, as defined,  
               that is not in remission, as defined, or cannot be kept in  
               remission without treatment; 
                 The severe mental disorder was one of the causes of or  
               was an aggravating factor in the commission of a crime, as  
               specified, for which the prisoner was sentenced to prison; 
                 The prisoner has been in treatment for the severe mental  
               disorder for 90 days or more within the year prior to the  
               prisoner's parole or release; and, 




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                 Prior to release on parole, the person in charge of  
               treating the prisoner and a practicing psychiatrist or  
               psychologist from the DSH or a chief psychiatrist of CDCR,  
               as applicable, have evaluated the prisoner at a CDCR  
               facility or state hospital, as applicable, and a chief  
               psychiatrist of CDCR has certified to BPH that the prisoner  
               meets the above criteria and that by reason of his or her  
               severe mental disorder the prisoner represents a  
               substantial danger of physical harm to others.  (Pen. Code  
               � 2962.) 

           Existing law  requires BPH to order a further examination by two  
          independent professionals, as specified, if the professionals  
          doing the evaluation described above do not concur that (i) the  
          prisoner has a severe mental disorder, (ii) that the disorder is  
          not in remission or cannot be kept in remission without  
          treatment, or (iii) that the severe mental disorder was a cause  
          of, or aggravated, the prisoner's criminal behavior, and a chief  
          psychiatrist has certified the prisoner to the BPH.  It further  
          requires the certification by a chief psychiatrist to stand if  
          at least one of the independent professionals who evaluate the  
          prisoner concurs with the chief psychiatrist's certification.   
          (Pen. Code � 2962, subds. (d)(2)- (3).) 

           Existing law  allows BPH, upon a showing of good cause, to order  
          an inmate to remain in custody for up to 45 days past the  
          scheduled release date for a full MDO evaluation.  (Penal Code �  
          2963.) 


           Existing law  allows the prisoner to challenge the MDO  
          determination both administratively (at a hearing before the  
          board) and judicially (via a superior court jury trial).  (Pen.  
          Code � 2966.) 


           Existing law  provides that if the MDO determination made by BPH  
          is reversed by a judge or jury, the court shall stay the  
          execution of the decision for five working days to allow for an  




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          orderly release of the person.  (Pen. Code � 2966.) 


           Existing law  requires MDO treatment to be inpatient treatment  
          unless there is reasonable cause to believe that the parolee can  
          be safely and effectively treated on an outpatient basis.   
          Existing law allows a parolee to request a hearing to determine  
          whether outpatient treatment is appropriate if the hospital does  
          not place the parolee on outpatient treatment within 60 days of  
          receiving custody of the parolee.  (Pen. Code � 2964, subds.  
          (a)-(b).) 


           Existing law  requires the director of the hospital to notify BPH  
          and discontinue treatment if the parolee's severe mental  
          disorder is put into remission during the parole period and can  
          be kept that way.  (Pen. Code � 2968.) 


          Existing law  allows the district attorney to file a petition in  
          the superior court seeking a one-year extension of the MDO  
          commitment.  (Pen. Code � 2970.) 


           Existing law  requires the following persons released from prison  
          on or after October 1, 2011, be subject to parole under the  
          supervision of CDCR: 

                 A person who committed a serious felony, as specified; 
                 A person who committed a violent felony, as specified; 
                 A person serving a Three-Strikes sentence; 
                 A high-risk sex offender; 
                 A mentally disordered offender; 
                 A person required to register as a sex offender and  
               subject to a parole term exceeding three years at the time  
               of the commission of the offense for which he or she is  
               being released; and, 
                 A person subject to lifetime parole at the time of the  
               commission of the offense for which he or she is being  




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               released.  (Pen. Code � 3000.08, subds. (a) & (c).) 

           Existing law  requires all other offenders released from prison  
          on or after October 1, 2011, to be placed on postrelease  
          community supervision under the supervision of a county agency,  
          such as a probation department.  (Pen. Code � 3000.08, subd.  
          (b).) 

           Existing law  provides that prior to a life inmate's initial  
          parole consideration hearing, a Comprehensive Risk Assessment  
          will be performed by a licensed psychologist employed by BPH,  
          except as specified.  (Cal. Code Regs., tit. 15, � 2240, subd.  
          (a).) 

           Existing law  provides that a Comprehensive Risk Assessment will  
          be completed every five years and will consist of both static  
          and dynamic factors which may assist a hearing panel or BPH in  
          determining whether the inmate is suitable for parole.  Existing  
          law provides that the assessment may include, but is not limited  
          to, an evaluation of the commitment offense, institutional  
          programming, the inmate's past and present mental state, and  
          risk factors from the prisoner's history and that the assessment  
          will provide the clinician's opinion, based on the available  
          data, of the inmate's potential for future violence.  It further  
          allows BPH psychologists to incorporate actuarially-derived and  
          structured professional judgment approaches to evaluate an  
          inmate's potential for future violence.  (Cal. Code Regs., tit.  
          15, � 2240, subd. (b).) 

          Existing law  states that in the 5-year period after a  
          Comprehensive Risk Assessment has been completed, life inmates  
          who are due for a regularly scheduled parole consideration  
          hearing will have a Subsequent Risk Assessment completed by a  
          licensed psychologist employed by BPH for use at the hearing;  
          however, this will not apply to documentation hearings, cases  
          coming before BPH en banc, progress hearings, 3-year reviews of  
          a 5-year denial, rescission hearings, postponed hearings, waived  
          hearings or hearings scheduled pursuant to court order, unless  
          the board's chief psychologist or designee, in his or her  




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          discretion, determines a new assessment is appropriate under the  
          individual circumstances of the inmate's case.  It provides that  
          the Subsequent Risk Assessment will address changes in the  
          circumstances of the inmate's case, such as new programming, new  
          disciplinary issues, changes in mental status, or changes in  
          parole plans since the completion of the Comprehensive Risk  
          Assessment but will not include an opinion regarding the  
          inmate's potential for future violence because it supplements,  
          but does not replace, the Comprehensive Risk Assessment.  (Cal.  
          Code Regs., tit. 15, � 2240, subd. (c).) 

           Existing law  requires, regardless of the length of time served,  
          a life prisoner to be found unsuitable for and denied parole if  
          in the judgment of the BPH panel, the prisoner will pose an  
          unreasonable risk of danger to society if released from prison,  
          with the following circumstances tending to indicate  
          unsuitability: 

                 Commitment offense (The prisoner committed the offense  
               in an especially heinous, atrocious, or cruel manner.); 
                 Previous record of violence; 
                 Unstable social history; 
                 Sadistic sexual offenses; 
                 Psychological factors (The prisoner has a lengthy  
               history of severe mental problems related to the offense.);  
               and, 
                 Institutional behavior.  (Cal. Code Regs., tit. 15, �  
               2281, subds. (a) & (c).) 

           This bill  requires an independent professional appointed by BPH  
          for purposes of determining parole suitability of a MDO, at the  
          request of the prisoner, to consult with a prisoner's primary  
          mental clinician, if any, before making a recommendation  
          concerning that prisoner to BPH.  This bill defines "primary  
          mental clinician," for purposes of this provision, to mean a  
          licensed psychiatrist, psychologist, or clinical social worker  
          who regularly treats the prisoner, including, but not limited  
          to, an employee of the State Department of State Hospitals or a  
          privately-hired person.




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           This bill  requires BPH, at any hearing where BPH considers a  
          Psychological Risk Assessment, as specified, as part of its  
          determination of whether to set, postpone, or rescind a parole  
          release date of a prisoner under a life sentence, at the request  
          of the prisoner under a life sentence, also consult with the  
          prisoner's primary mental clinician if that person exists.   
          Defines "primary mental clinician," for purposes of this  
          provision, to mean a licensed psychiatrist, psychologist, or  
          clinical social worker who regularly treats the prisoner,  
          including, but not limited to, a state employee or a  
          privately-hired person.

                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION

          For the last several years, severe overcrowding in California's  
          prisons has been the focus of evolving and expensive litigation  
          relating to conditions of confinement.  On May 23, 2011, the  
          United States Supreme Court ordered California to reduce its  
          prison population to 137.5 percent of design capacity within two  
          years from the date of its ruling, subject to the right of the  
          state to seek modifications in appropriate circumstances.   

          Beginning in early 2007, Senate leadership initiated a policy to  
          hold legislative proposals which could further aggravate the  
          prison overcrowding crisis through new or expanded felony  
          prosecutions.  Under the resulting policy, known as "ROCA"  
          (which stands for "Receivership/ Overcrowding Crisis  
          Aggravation"), the Committee held measures that created a new  
          felony, expanded the scope or penalty of an existing felony, or  
          otherwise increased the application of a felony in a manner  
          which could exacerbate the prison overcrowding crisis.  Under  
          these principles, ROCA was applied as a content-neutral,  
          provisional measure necessary to ensure that the Legislature did  
          not erode progress towards reducing prison overcrowding by  
          passing legislation, which would increase the prison population.  
            

          In January of 2013, just over a year after the enactment of the  




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          historic Public Safety Realignment Act of 2011, the State of  
          California filed court documents seeking to vacate or modify the  
          federal court order requiring the state to reduce its prison  
          population to 137.5 percent of design capacity.  The State  
          submitted that the, ". . .  population in the State's 33 prisons  
          has been reduced by over 24,000 inmates since October 2011 when  
          public safety realignment went into effect, by more than 36,000  
          inmates compared to the 2008 population . . . , and by nearly  
          42,000 inmates since 2006 . . . ."  Plaintiffs opposed the  
          state's motion, arguing that, "California prisons, which  
          currently average 150% of capacity, and reach as high as 185% of  
          capacity at one prison, continue to deliver health care that is  
          constitutionally deficient."  In an order dated January 29,  
          2013, the federal court granted the state a six-month extension  
          to achieve the 137.5 % inmate population cap by December 31,  
          2013.  

          The Three-Judge Court then ordered, on April 11, 2013, the state  
          of California to "immediately take all steps necessary to comply  
          with this Court's . . . Order . . . requiring defendants to  
          reduce overall prison population to 137.5% design capacity by  
          December 31, 2013."  On September 16, 2013, the State asked the  
          Court to extend that deadline to December 31, 2016.  In  
          response, the Court extended the deadline first to January 27,  
          2014 and then February 24, 2014, and ordered the parties to  
          enter into a meet-and-confer process to "explore how defendants  
          can comply with this Court's June 20, 2013 Order, including  
          means and dates by which such compliance can be expedited or  
          accomplished and how this Court can ensure a durable solution to  
          the prison crowding problem."

          The parties were not able to reach an agreement during the  
          meet-and-confer process.  As a result, the Court ordered  
          briefing on the State's requested extension and, on February 10,  
          2014, issued an order extending the deadline to reduce the  
          in-state adult institution population to 137.5% design capacity  
          to February 28, 2016.  The order requires the state to meet the  
          following interim and final population reduction benchmarks:





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                 143% of design bed capacity by June 30, 2014;
                 141.5% of design bed capacity by February 28, 2015; and
                 137.5% of design bed capacity by February 28, 2016. 

          If a benchmark is missed the Compliance Officer (a position  
          created by the February 10, 2016 order) can order the release of  
          inmates to bring the State into compliance with that benchmark.   


          In a status report to the Court dated May 15, 2014, the state  
          reported that as of May 14, 2014, 116,428 inmates were housed in  
          the State's 34 adult institutions, which amounts to 140.8% of  
          design bed capacity, and 8,650 inmates were housed in  
          out-of-state facilities.   

          The ongoing prison overcrowding litigation indicates that prison  
          capacity and related issues concerning conditions of confinement  
          remain unresolved.  While real gains in reducing the prison  
          population have been made, even greater reductions may be  
          required to meet the orders of the federal court.  Therefore,  
          the Committee's consideration of ROCA bills -bills that may  
          impact the prison population - will be informed by the following  
          questions:

                 Whether a measure erodes realignment and impacts the  
               prison population;
                 Whether a measure addresses a crime which is directly  
               dangerous to the physical safety of others for which there  
               is no other reasonably appropriate sanction; 
                 Whether a bill corrects a constitutional infirmity or  
               legislative drafting error; 
                 Whether a measure proposes penalties which are  
               proportionate, and cannot be achieved through any other  
               reasonably appropriate remedy; and,
                 Whether a bill addresses a major area of public safety  
               or criminal activity for which there is no other  
               reasonable, appropriate remedy.

                                      COMMENTS




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          1.    Need for this Bill  

          According to the author:
                Existing law allows a prisoner to request a hearing  
                from the Board of Parole Hearings to make the case of  
                why they should be given parole.  The law requires  
                that a prisoner who is being considered for parole  
                within the California Department of Corrections and  
                Rehabilitation (CDCR), be evaluated by a certified  
                clinician prior to a parole hearing. 

                If it is determined that the prisoner should receive a  
                parole hearing, existing law requires that the  
                clinician in charge of treating the prisoner and an  
                independent evaluator from within the California  
                Department of Corrections and Rehabilitation (CDCR),  
                evaluate the prisoner.  The law also requires the  
                Board of Parole Hearings to appoint two independent  
                professionals to conduct an additional review in  
                certain circumstances.

                However, these independent evaluators are not required  
                to consult with a prisoner's primary clinician before  
                making a recommendation to the board.  The findings of  
                these evaluators may be incomplete or lack context  
                since they may not know the unique circumstances  
                facing the prisoner.

                My bill would require the independent evaluator from  
                CDCR to consult with the prisoner's primary clinician  
                before making a recommendation to the Board of Parole  
                Hearings.  This would help ensure public safety and  
                the well-being of the prisoner by improving  
                communication between the prisoner's health team and  
                independent evaluators.

          2.  The Mentally Disordered Offender Act (Penal Code section 2960  
            et seq.)  




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          A MDO commitment is a post-prison civil commitment.  The MDO Act  
          is designed to confine as mentally ill an inmate who is about to  
          be released on parole when it is deemed that he or she has a  
          mental illness which contributed to the commission of a violent  
          crime.  Rather than release the inmate to the community, CDCR  
          paroles the inmate to the supervision of the state hospital, and  
          the individual remains under hospital supervision throughout the  
          parole period.  The act actually addresses treatment in three  
          contexts - first, as a condition of parole (Pen. Code, � 2962);  
          then, as continued treatment for one year upon termination of  
          parole (Pen. Code � 2970); and, finally, as an additional year  
          of treatment after expiration of the original, or previous,  
          one-year commitment (Pen. Code � 2972).  (People v. Cobb (2010)  
          48 Cal.4th 243, 251.)  

          Penal Code section 2962 lists six criteria that must be proven  
          for an initial MDO certification, namely, whether: (1) the  
          inmate has a severe mental disorder; (2) the inmate used force  
          or violence in committing the underlying offense; (3) the severe  
          mental disorder was one of the causes or an aggravating factor  
          in the commission of the offense; (4) the disorder is not in  
          remission or capable of being kept in remission without  
          treatment; (5) the inmate was treated for the disorder for at  
          least 90 days in the year before the inmate's release; and (6)  
          by reason of the 


          severe mental disorder, the inmate poses a serious threat of  
          physical harm to others. (Pen. Code 
          � 2962, subds. (a)-(d); People v. Cobb, supra, 48 Cal.4th at p.  
          251-252.)

          The initial determination that the inmate meets the MDO criteria  
          is made administratively.  The person in charge of treating the  
          prisoner and a practicing psychiatrist or psychologist from the  
          DSH will evaluate the inmate.  If it appears that the inmate  
          qualifies, the chief psychiatrist then will certify to BPH that  
          the prisoner meets the criteria for an MDO.




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          The inmate may request a hearing before BPH to require proof  
          that he or she is an MDO.  If BPH determines that the defendant  
          meets the criteria of an MDO, the inmate may file, in the  
          superior court of the county in which he or she is incarcerated  
          or is being treated, a petition for a hearing on whether he or  
          she, as of the date of the board hearing, meets the criteria of  
          a MDO.  By statute, the defendant is entitled to a jury trial,  
          which can be waived.  The jury must unanimously agree it was  
          proven beyond a reasonable doubt that the allegations of the  
          petition were proven.  If the superior court or jury reverses  
          the determination of BPH, the court is required to stay the  
          execution of the decision for five working days to allow for an  
          orderly release of the prisoner.  
             
          MDO treatment must be on an inpatient basis, unless there is  
          reasonable cause to believe that the parolee can be safely and  
          effectively treated on an outpatient basis.  But if the parolee  
          can no longer be safely and effectively treated in an outpatient  
          program, he or she may be taken into custody and placed in a  
          secure mental health facility.

          An MDO commitment is for one year; however, the commitment can  
          be extended.  (Pen. Code 
          � 2972, subd. (c).)  When the individual is due to be released  
          from parole, the state can petition to extend the MDO commitment  
          for another year.  The state can file successive petitions for  
          further extensions, raising the prospect that, despite the  
          completion of a prison sentence, the MDO may never be released.  

           3.  Use of Psychological Evaluations in Parole Hearings and Parole  
            Decisions  

          In 2011, the Stanford Criminal Justice Center studied the parole  
          process and outcomes of California prison inmates sentenced to  
          life with the possibility of parole.  In examining the results  
          of parole determinations, the researchers found that the  
          psychological evaluations used to assess an inmate's  
          psychological stability and risk potential played an influential  




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          role in whether parole was granted or denied.  (Weisberg, et  
          al., Life in Limbo: An Examination of Parole Release for  
          Prisoners Serving Life Sentences with the Possibility of Parole  
          in California, Stanford Criminal Justice Center (Sept. 2011) p.  
          23-24.)  Specifically, the report stated the following:  

                Virtually all inmates who appear at parole hearings  
               have undergone psychological evaluations.  Parole  
               commissioners always receive and often review the  
               results of these evaluations carefully. 

               The two most common types of clinical opinions in our  
               sample are the Axis V Global Assessment of Functioning  
               Scale and the Clinician Generic Risk assessment.  The  
               Axis V GAF measures a patient's overall level of  
               psychological, social, and occupational functioning on  
               a 100-point continuum, with higher scores indicating  
               higher functioning.  The Clinician Generic Risk, by  
               contrast, assigns inmates a simple  
               risk-of-recidivating score: low, low-moderate,  
               moderate, moderate-high, and high.

               ? Both the Clinician Generic Risk and the Axis V-GAF  
               are significantly correlated with grant rate. This is  
               especially true of the Clinician Generic Risk  
               assessment, which is statistically significant at the  
               .001 level.  [I]nmates who receive an average score or  
               higher virtually never receive parole release.   
               Similarly, none of the inmates in our sample who  
               received below 75 on the Axis V-GAF enjoyed favorable  
               release outcomes.  (Id. at p. 23.)












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            This bill would require BPH to consult with an inmate's  
            primary mental clinician as part of its determination of  
            whether to set, postpone, or rescind a parole release date of  
            an inmate serving a life sentence with the possibility of  
            parole, if the inmate so requests.  Additionally, this bill  
            would require an independent mental health evaluator to  
            consult with a MDO inmate's primary mental clinician, at the  
            request of the inmate, in making a recommendation to BPH about  
            the inmate's psychological state.  Some stakeholders express  
            concern that requiring consultation with the primary mental  
            clinician might pressure the independent evaluator to adopt  
            the clinician's diagnoses or findings of the inmate's mental  
            condition or unfairly prejudice the prisoner from obtaining  
            what otherwise might be a grant of parole.  Considering,  
            however, that this bill requires consultation with the primary  
            mental clinician only at the request of the inmate, and that  
            an inmate would request the consultation likely only when it  
            would be favorable to the inmate and not when it would reveal  
            disadvantageous information, this bill could result in BPH  
            receiving more favorable information about an inmate than the  
            board otherwise would have in making a parole determination.   
            Moreover, given the greater familiarity a primary treating  
            clinician has with the mental health of an inmate and the  
            strong correlation an inmate's psychological evaluation has  
            with parole determinations, the consultation required by this  
            bill may provide BPH with a more thorough evaluation of the  
            inmate.
             
             4.    Argument in Support

            The American Federation of School, County and Municipal  
            Employees (AFSCME), Local 2620 states in support:
             
                Currently, independent evaluators charged with  
               evaluating a prisoner prior to a lifer parole hearing  
               or release on parole from a determinate term review  
               the medical chart and interview the inmate.   
               Independent evaluators do not consult with the primary  
               clinician who has been treating the inmate, thus  




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               providing an incomplete assessment of the inmate's  
               progress or condition.  

               The purpose of this bill is not to influence  
               decisions, but to create a more accurate evaluation of  
               the inmate by providing the outside evaluator with the  
               assessment of the primary clinician, the profession  
               who knows the inmate better than the outside  
               evaluator.  This will produce a better representation  
               of whether the inmate is suitable for parole or  
               release without mandatory treatment.
             
             5.    Argument in Opposition

             The California Public Defenders Association states in  
            opposition:

               AB 2520 requires that appointed independent mental  
               health expert appointed to evaluate an inmate as a  
               possible mentally disordered offender consult with the  
               inmate's treating therapist, psychologist or  
               psychiatrist.  The legislation appears to ensure that  
               the treating therapist's viewpoint is unfairly  
               weighted so as to defeat the balanced scheme in  
               existing law that protects the public and the rights  
               of the inmate.  The whole process begins when the  
               treating therapist opines that an inmate is an MDO.   
               Requiring independent evaluators consult with the  
               treating therapist undermines the independence of the  
               evaluators. 

               Specifically, under the terms of the governing law,  
               the treating psychologist - or even the chief  
               psychiatrist if he or she is the treating physician -  
               has already evaluated the inmate and rendered an  
               opinion that the inmate is an MDO.  At that point, the  
               inmate is evaluated by the treating clinician at CDCR  
               and a DSH psychologist or psychiatrist.  If one of the  
               evaluators finds that the inmate is an MDO, but the  











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               other does not, the vote of the chief psychiatrist at  
               CDCR - who may be the treating physician - breaks the  
               tie of the two initial evaluators.  At the next step,  
               two independent evaluators are appointed.  By  
               mandating that the independent evaluators consult the  
               treating therapist, psychologist or psychiatrist, but  
               not the other mental health evaluators who have opined  
               that the inmate is not an MDO, the bill would put  
               pressure on the independent evaluators to adopt the  
               treating professional's viewpoint.  The treating  
               therapist must have opined that the inmate is an MDO,  
               or the chief psychiatrist would not have certified  
               that finding.  
             
           
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