P. v. Phillips CA1/2
Appellant Donald Phillips appeals from the trial court’s order extending his civil commitment at Napa State Hospital under Penal Code section 1026.5 until April 30, 2018. Appellant first contends—and respondent agrees—that the court erred when it extended his commitment to April 30, rather than April 1, which was two years from the date his prior commitment extension was due to expire. He further contends the court improperly permitted three expert witnesses to testify to case-specific facts that were based on inadmissible hearsay; the court erred when it permitted a prosecution expert to testify about the procedure for early release from a state hospital; and the cumulative effect of these errors requires reversal. We shall modify the order extending appellant’s commitment such that it will expire on April 1, 2018, but shall otherwise affirm the trial court’s order extending appellant’s commitment for two years.
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