People v. Patton CA4/3

Filed 5/7/25 P. v. Patton CA4/3

NOT TO BE PUBLISHED IN OFFICIAL REPORTS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 This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.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

FOURTH APPELLATE DISTRICT

DIVISION THREE

THE PEOPLE,

Plaintiff and Respondent, G063264

v. (Super. Ct. No. 94HF0955)

LEONARD JAMES PATTON, OPINION

Defendant and Appellant.

Appeal from a postjudgment order of the Superior Court of Orange County, Erin Rowe, Judge. Affirmed. John L. Staley under appointment by the Court of Appeal, for Defendant and Appellant. Rob Bonta, Attorney General, Lance E. Winters, Chief Assistant Attorney General, Charles C. Ragland, Assistant Attorney General, Steve Oetting and Evan Stele, Deputy Attorneys General, for Plaintiff and Respondent.

Over 30 years ago, Leonard James Patton murdered a woman while suffering from schizoaffective disorder. He was found not guilty by reason of insanity and was committed to a state hospital. In 2023, hospital staff recommended that Patton be transferred to outpatient treatment. The trial court held an evidentiary hearing and denied the transfer, finding Patton had not shown he is no longer a danger to the community. Patton asserts the trial court erred by improperly placing the burden of proof on him, by applying the wrong standard in evaluating the transfer recommendation, and by disapproving the transfer. We disagree. The court properly assigned the burden of proof to Patton, the record confirms the court understood and applied the correct standard, and the court did not abuse its discretion in disapproving the recommendation. We therefore affirm the order denying outpatient status. FACTS In 1993, Patton began experiencing increasingly severe paranoid delusions as a result of schizoaffective disorder, a combination of schizophrenia and bipolar disorder that results in mood swings and paranoid delusions. He fell into a cycle of engaging in impulsive criminal behavior, receiving psychiatric treatment, not taking his prescribed psychotropic medications, and then experiencing worsening symptoms. In 1994, Patton impulsively traveled from Minnesota to Orange County, where he murdered a woman with a tire iron because he believed she was a government agent conspiring to get him. He pleaded guilty to first degree murder, but the trial court found him not guilty by reason of insanity. He was then committed to a state hospital. In 2006, Patton was released to community outpatient treatment. However, his outpatient status was revoked less than a year later because he