California, United States of America
The following excerpt is from People v. Planavsky, 40 Cal.App.4th 1300, 47 Cal.Rptr.2d 723 (Cal. App. 1995):
Most recently, People v. Young (1991) 228 Cal.App.3d 171, 278 Cal.Rptr. 784 faced the problem of a trial court's supposed "failure" to consider civil commitment when a defendant fails to request it. In Young the defendant made no request for civil commitment under section 3051, but then claimed on appeal that it was error not to consider him for it anyway.
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