People v. C.F.

── People v. C.F. ── Court: California Court of Appeal Date: April 17, 2026 Category: General Filed 4/17/26 CERTIFIED FOR PUBLICATION IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA FIRST APPELLATE DISTRICT DIVISION FIVE THE PEOPLE, Plaintiff and Respondent, A174372 v. (Napa County Super. Ct. No. 25PR000108) C.F., Defendant and Appellant. Defendant C.F. appeals from a trial court order granting plaintiff Department of State Hospitals’ (Department) petition for renewal of an order authorizing the treatment of C.F. with antipsychotic medication. At the evidentiary hearing on the petition, there was no court reporter because C.F.’s trial counsel did not request one even though the court would have provided a reporter free of charge if counsel had done so. Lacking a reporter’s transcript, C.F. applied for a settled statement but the court denied his application. On appeal, C.F. contends that the order granting the petition should be reversed because he received ineffective assistance of counsel. We agree and reverse. Because it is too late for C.F. to get a settled statement before that order expires, we remand for a new hearing. BACKGROUND C.F. was admitted to Napa State Hospital after being found not guilty by reason of insanity (Pen. Code, § 1026). Pursuant to a court order, the Department began treating C.F. with antipsychotic medication. 1  On May 21, 2025, the Department filed a verified petition to renew the “order authorizing treatment with antipsychotic medication for” C.F. (Petition). The trial court appointed counsel for C.F. and held an evidentiary hearing on the Petition on June 25, 2025. C.F.’s trial counsel did not request a court reporter before the hearing even though he could have obtained one free of charge under the trial court’s local rules by completing and submitting a one-page form.1 As a result, there was no court reporter at the hearing. C.F. also refused to appear, and his counsel waived his appearance. According to the minute order, C.F.’s counsel orally objected “to the hearing not being recorded” and moved to have the hearing “recorded.” The court overruled the objection and denied the motion “without prejudice.” The court further “indicate[d] that the matter of recording the hearings would need to be fully briefed to be reconsidered.” The trial court then proceeded with the hearing without a court reporter or recording. The Department called one witness, Dr. Raman Sharma. The parties stipulated that Dr. Sharma was “an expert in the field of [p]sychiatry,” and she testified for about 13 minutes. The record does not include the substance of her testimony. C.F. called no witnesses. After the close of evidence, the court granted the Petition, finding “by clear and convincing evidence that [C.F.] lacks capacity to refuse treatment.” It then ordered that C.F. “be involuntarily administered antipsychotic medication by 1 We grant the Department’s unopposed Motion for Judicial Notice and take judicial notice of the court’s reporting services rule and form for requesting a court reporter. We also grant C.F.’s unopposed Motion to Augment and Correct the Record—which seeks to augment the record with four documents filed in the trial court relating to his Application for Permission to Prepare Settled Statement (Application). Finally, we deny C.F.’s motion to strike certain factual findings in the order denying the Application. In doing so, we express no opinion as to the propriety or validity of those findings. 2 the” Department “for the period-of-time not to exceed one year from” June 25, 2025. C.F. timely appealed. On December 8, 2025, C.F. filed the Application. The Department opposed, arguing that C.F. waived his right to a