In Coburn v. Sievert (2005) 133 Cal.App.4th 1483, Dwight Sievert, M.D., the psychiatrist directly responsible for the treatment of Edward Coburn, released Coburn early from an involuntary 72-hour hold. (Id. at p. 1488.) The day after his early release, Coburn had a violent outburst on an airplane with his father that resulted in criminal prosecution, civil lawsuits, property damage, and further confinement and treatment of Coburn. (Id. at p. 1489.) Coburn and his father sued Sievert for damages arising from the acts Coburn committed on the airplane, and the " 'only theories being pursued were based on negligent diagnosis, treatment, staffing, medication, release, and failure to confine.' " (Id. at pp. 1488, 1490, fn. 3.) The trial court granted summary judgment in favor of Sievert on the ground that he was immune from liability under section 5154, subdivision (a), because he met the conditions for early release set forth in section 5152, i.e., he was the treating psychiatrist who authorized the early release because he believed, based on his personal observations, that Coburn no longer required evaluation or treatment. (Id. at p. 1488; see also p. 1504 the psychiatrist's belief that the patient no longer requires evaluation or treatment need not be objectively reasonable.) On appeal, Coburn argued that the requirement under section 5154, subdivision (a), that "the provisions of Section 5152" be met means that all of the provisions in section 5152, and not just the matters explicitly relating to early release, must be met for the immunity to apply. (Coburn, supra, 133 Cal.App.4th at p. 1497.) He argued Sievert was not entitled to immunity because he did not meet the requirement in the first sentence of section 5152, subdivision (a), "that the patient receive the evaluation, . . . care and treatment his condition requires while confined." (Coburn, supra, at p. 1498.) Sievert argued "that the other sentences in subdivision (a) of section 5152 as well as the entirety of subdivisions (b) and (c) were not 'provisions of Section 5152.' " (Coburn, supra, at p. 1498.) The Court of Appeal agreed with Sievert, stating that the legislative history revealed a latent ambiguity as to the term "the provisions of section 5152." (Id. at pp. 1500, 1501-1502.) Noting that a psychiatrist who releases a patient at the end of a 72-hour hold is unqualifiedly immune from liability under section 5154, subdivision (b), the court stated, "a statutory construction that creates immunities of such different scope based on whether the release was early or at the end of the detention period is suspect because the balance of the competing interests struck in one situation is so different from the balance struck in the other situation, and the difference itself appears to undercut rather than further the purposes of the . . . Act." (Coburn, supra, 133 Cal.App.4th at p. 1501.) The court stated, "To promote consistency between the availability of immunity provided for early release and the immunity provided for release at the end of a holding period, and bearing in mind that one of the stated purposes of the . . . Act is to 'end the inappropriate, indefinite, and involuntary commitment of mentally disordered persons' ( 5001, subd. (a)), we conclude the additional conditions imposed by the qualification 'if the provisions of Section 5152 have been met' must be construed to mean only those conditions relating to early release." (Coburn, supra, 133 Cal.App.4th at p. 1501.) In Coburn, the court questioned whether immunity under section 5154 would protect a psychiatrist for "injuries that, while they may occur after an early release, are caused by negligent treatment during the detention rather than by actions of the person released." (Coburn, supra, 133 Cal.App.4th at p. 1502.) It examined two hypothetical situations, one in which a psychiatrist prescribes a medication that causes the patient to suffer a heart attack while driving, which in turn results in injury to the patient and an innocent bystander, and another in which a psychiatrist sexually assaults a detained patient which causes the patient to commit suicide after being granted an early release. (Id. at pp. 1502-1503.) "While . . . suspecting that application of section 5154 to support immunity in these hypothetical situations might give the legislation unintended scope," Coburn concluded, "we mention the hypothetical situations here largely to limit the scope of this opinion to the facts that are presented. Plaintiffs suggest no facts that would support a conclusion that Sievert engaged in any conduct or treatment of Coburn that itself caused Coburn's subsequent actions. Rather, all of plaintiffs' facts show nothing more than a failure to diagnose, a failure to treat, and a release that was negligent because of those failures. We therefore need explore no further this subject, which of course includes complicated questions of legal causation. Plaintiffs appear to have correctly conceded, in listing the facts alleged by Sievert with which they did and did not agree, that this case involves liability for injuries arising out of the actions of Coburn." (Id. at p. 1503.)