COONEY v. CITY OF SAN DIEGO
DEBORAH COONEY, Plaintiff and Appellant,
CITY OF SAN DIEGO et al., Defendants and Respondents.
Court of Appeals of California, Fourth District, Division One.
Filed March 28, 2012.
NOT TO BE PUBLISHED IN OFFICIAL REPORTS
Deborah Cooney was involuntarily detained overnight in the San Diego County Psychiatric Hospital after police officers brought her to the hospital based on reports she had created a disturbance while swimming in the ocean and after a hospital psychiatrist found she should be committed for evaluation under Welfare and Institutions Code section 5150.1 Under section 5150, a person may be involuntarily committed to a county-designated facility for 72 hours if there is probable cause to believe the individual, "as a result of a mental disorder, is a danger to others, or to himself or herself, or is gravely disabled."
Claiming her detention and confinement were without probable cause, Cooney brought a civil action against the County of San Diego (County), the City of San Diego (City), and City lifeguard John Kerr. Cooney alleged several causes of action, including false arrest, false imprisonment, assault and battery, negligent infliction of emotional distress, negligence, and libel/slander. Defendants successfully moved for summary judgment. Cooney appeals. We affirm.FACTUAL AND PROCEDURAL SUMMARY
The nature of Cooney's legal claims requires that we focus on the facts known to defendants at the time of their challenged actions. We thus summarize the background facts from this perspective. We view these facts in the light most favorable to Cooney, the party opposing the summary judgment.A. Background