Free Britney! Child Stars Under Conservatorship

How legal reform protects show biz kids

Emily Weisberg

The #FreeBritney movement captured the world’s attention in summer 2021. In videos posted on social media, fans obsessively tried to interpret the hidden meaning behind Britney Spears’ every Instagram post. In news articles, journalists similarly tracked developments in Spears’ case by parsing through her father’s legal filings submitted in his efforts to remain sole conservator. Additionally, Miley Cyrus, Paris Hilton, Ariel Winter, the American Civil Liberties Union and over 190,000 others called to release Britney from the conservatorship.[1] How did the conservatorship of one individual—albeit one very famous individual—garner so much attention from so many different people and organizations?

For the purposes of clarity and not out of disrespect, I will refer to Britney Spears as Britney and her father Jamie Spears as Jamie for the remainder of the article.

On February 1, 2008, a court placed Britney under a conservatorship and appointed Jamie and attorney Andrew M. Wallet as co-conservators. Britney was placed under the conservatorship because of concerns about her mental health due to a series of public incidents, including a hospitalization for mental health reasons in 2007.[2] In 2021, the singer successfully ended her 13-year conservatorship.[3] The media frenzy around Britney’s conservatorship led to the “#FreeBritney” movement––raising concerns among experts, the public and the entertainment industry as a whole as to whether conservatorships are really the best solution for Hollywood’s troubled young entertainers.[4]

To gain her freedom, Britney had to navigate conservatorship law to successfully terminate her father’s power over her estimated $60 million estate.[5] Britney and her legal team allege that she was subjected to financial misconduct, forced musical performances, forced medications and forced use of a contraceptive device. Jamie has denied these allegations. Britney's undertaking prompted another young celebrity in Hollywood, former Nickelodeon child star Amanda Bynes, to terminate her nearly nine-year conservatorship in March 2022.[6]

The publicity surrounding these two cases has raised concerns about how to protect other young celebrities from the fate that Spears and Bynes endured. This in turn has caused state and federal legislatures and independent government agencies to take action, leaving the future of conservatorships uncertain but hopefully changing for the better.

History of Conservatorships in California

A conservatorship is one of a number of legal arrangements in which a person can assume legal guardianship over an adult.[7] However, unlike Spears, most people under conservatorships are elderly and unable to take care of their basic everyday needs. State laws govern conservatorships, and each state’s laws vary greatly.[8] Unfortunately for Britney and others in California, California conservator law is particularly complex. The Superior Court of California defines a conservatorship as a court proceeding wherein a judge appoints a “responsible person to care for another adult who cannot care for him/herself or his/her finances.”[9]

Prior to 1957, there were no conservatorships in California.[10] Instead, there were two types of guardianships: guardianships of the person and guardianships of the estate.[11] A guardianship of the person describes a legal situation in which one person is in charge of another.[12] Meanwhile, a guardianship of the estate describes a legal situation in which one person is in charge of another’s real property, money and business affairs.[13] These roles were often combined, and a guardian could be appointed to either an adult or child who was deemed “incompetent.”[14]

Conservatorships in California are not all the same. There are currently four different types of conservatorships in California: general conservatorship, the Lanterman-Petris-Short Act conservatorship, limited conservatorship and temporary conservatorship.

General Conservatorship

The first and earliest form of conservatorship in California is the general conservatorship, created in 1957 as an alternative to guardianship.[15] It is for an adult who "by reason of advanced age, illness, injury, mental weakness, intemperance, addiction to drugs or other disability or other cause is unable properly to care for himself or for his property, or who for said causes or for any other cause is likely to be deceived or imposed upon by artful or designing persons.”[16]  Therefore, general conservatorships are commonly for seniors or seriously impaired young people, such as victims of car accidents.

LPS Conservatorship

In 1967, the Lanterman-Petris-Short (LPS) Act created a second type of conservatorship, an LPS conservatorship, for people who are seriously disabled because of some sort of mental disorder.[17] The LPS Act sought to end the often “inappropriate, indefinite, and involuntary commitment of persons with mental health disorders.”[18] LPS conservators have a lot of powers, including consenting to the use of mind altering drugs on behalf of conservatees and placing them “in a locked facility if the psychiatrist says it is needed and the hospital agrees to take the person, whether or not the conservatee agrees.”[19]

Limited Conservatorship

In 1980, California established a limited conservatorship, a third type of conservatorship.[20] This type of conservatorship is for the “developmentally disabled adult.”[21] A conservatee under a limited conservatorship can “usually do many more things than a person under an LPS conservatee.”[22] Generally, conservatees in a limited conservatorship need less help with everyday tasks and managing their assets than conservatees in general conservatorships.[23]

Temporary Conservatorship

The fourth type of conservatorship is the temporary conservatorship.[24] Courts typically create temporary conservatorships when a person needs immediate help.[25] A judge can order a temporary conservatorship to be put in place while the issue of conservatorship is pending in court or to take care of a “conservatee [with] more immediate needs that cannot wait” until a permanent conservator is appointed.[26] A temporary conservator arranges for the conservatee’s temporary care, protection and support until a permanent conservator can be appointed.[27]

 Today, California courts offer all four types of conservatorships, the most common among them being the general and limited.[28]

Why Was Britney Placed Under a Conservatorship?

The podcast Britney’s Gram and blogger Anthony Elia popularized the Free Britney movement and the #FreeBritney hashtag.[29] However, the podcast and blog later shut down after Britney’s conservatorship initiated a defamation lawsuit against Elia. [30]  The complaint stated, “It’s time for the conspiracy theories. . .and the mob #FreeBritney movement to stop.” [31]

Britney Spears, known as the “Princess of Pop,” is one of the most famous celebrities in the world. In 2021, she began to speak openly on social media about the alleged abuse she suffered at the hands of her own father while subject to a conservatorship. Some of the allegations included abuse, conflicts of interest, financial mismanagement, not being allowed to get married, being forced to have an intrauterine contraceptive (IUD), and corruption of the conservatorship.[32] However, Jamie has repeatedly denied allegations of abuse.[33] How could something like this allegedly happen to someone as famous as Britney?

On November 7, 2006, Britney Spears filed for divorce from Kevin Federline, citing irreconcilable differences.[34] Britney developed signs of erratic behavior, including hard partying, following the divorce, and photographers caught her driving around with her infant son in her lap instead of a car seat.[35] Additionally, in 2007 Britney shaved her head and attacked a paparazzo’s car with an umbrella.[36] Spears was subsequently hospitalized under a 5150 hold, “an emergency psychiatric hold, in which a person having a mental episode can be involuntarily hospitalized.”[37] As a result of the hold, Britney lost custody of and visitation rights to her children.[38]

Following the involuntary hold, Britney’s parents, Jamie and Lynne, consulted lawyers to help them establish a conservatorship.[39] Britney’s parents worried that her new manager, Sam Lutfi, might be stealing money from Britney and that his choices might leave her in “serious debt.”[40] Lutfi has denied these allegations.[41] A second involuntary hold quickly followed on January 31, 2008, when Spears was rushed to the hospital in an ambulance.[42] Concerned, Jamie decided it was time to move forward with the conservatorship.[43] The following morning, while Britney was still in the hospital, Jamie, Lynne and Jacqueline Butcher, a then-friend of the Spears family, went to a courtroom and petitioned for a conservatorship.[44]

The presiding judge, Judge Reva Goetz, immediately granted the petition, bypassing California’s typical five days’ notice requirement and waiving the requirement that Britney be notified.[45] Judge Goetz appointed two co-conservators to oversee the conservatorship: Jamie and Andrew Wallet, a lawyer.[46] Lynne did not try to become a co-conservator because, according to her, the conservatorship was only supposed to last for a limited period of time.[47] According to Ms. Butcher, the whole process took “maybe ten minutes” in which “no one testified” and “no questions were asked.”[48]

In the following days, Britney attempted to hire legal counsel to remove Jaime as conservator, but Judge Goetz ruled that Britney “had no capacity to retain an attorney” of her choosing.[49] Instead, Judge Goetz appointed Samuel Ingham, a probate lawyer, as Britney’s advocate.[50] Given the case’s “unusual problems requiring extraordinary expertise,” the court paid Ingham a higher fee than is usual for appointed attorneys, with the New York Times estimating that Ingham has made $3 million from Britney’s case alone.[51]

Wallet resigned as co-conservator in 2019, leaving Jamie as sole conservator.[52] In August and September 2020, Ingham filed requests by Britney to remove Jamie as conservator and nominate financial company Bessemer Trust as his replacement, arguing that California Probate Code section 1810 gave Britney the right to nominate a conservator of her choosing.[53] Section 1810 requires a court to appoint such a nominee unless the appointment is not in the conservatee’s best interest.[54]

Meanwhile, Britney went public with her abuse claims.[55] Her candor shocked observers as she had not publicly expressed her true feelings about the conservatorship for the majority of the time she was under its grip.[56] In June 2021, Britney made clear her desire to terminate the conservatorship altogether, rather than simply replace Jamie.[57] There was just one problem: a petition to terminate would likely involve an investigation into whether Britney had the mental capacity required to make such a request, and Ingham had previously expressed great skepticism about his client’s mental state.[58] Amid this confusion, Ingham resigned.[59]

Judge Brenda Penny—who had taken over the matter from Judge Goetz back in 2016—allowed Britney to retain her own attorney.[60] Britney selected attorney Matthew Rosengart, who then side-stepped the issue of termination and instead focused his efforts on aggressively trying to get Jamie replaced.[61] This strategy succeeded: on August 12, 2021, Jamie, facing pressure from Rosengart and the public, reluctantly agreed to step down.[62] In a surprise move on September 7, 2021, Jamie went further, asking the court to terminate the 13-year conservatorship.[63] Finally, in November 2021, Judge Penny agreed to end the conservatorship.[64] Judge Penny made her ruling in less than 30 minutes, holding that further psychological assessments were unnecessary.”[65]

Other Examples of Hollywood Conservatorships

Britney is not the only Hollywood celebrity who has been subjected to a conservatorship. Others include Amanda Bynes, Brian Wilson, Joni Mitchell, Randy Meisner and Mickey Rooney.[66] While Rooney used principles of elder abuse law to escape his situation, Bynes’ situation was comparable to Britney’s. A court put Bynes’ mother, Lynn, in charge of Bynes’ estimated $5 million fortune after Bynes had been arrested for several DUIs and placed under a thirty-day psychiatric hold between 2012 and 2014.[67] In March 2022, a California judge terminated Bynes’ conservatorship, ending a nearly decade-long legal arrangement.[68] Bynes states that she is “excited” about her upcoming endeavors post-conservatorship.[69]

But not all celebrity conservatorships have a parent-child dynamic. In 2015, Joni Mitchell suffered an aneurysm which left her unable to speak.[70] During her recovery, a friend of Mitchell’s was reportedly responsible for providing temporary support, but the friend was unable to take possession of money or property without a specific court order.[71]In another case, Beach Boys founder Brian Wilson was put under a conservatorship after his longtime, live-in psychologist allegedly manipulated him and never properly treated him for alcohol and drug use, obesity, and a schizo-affective disorder.[72]

Legal Reasons Why Conservatorships Exist

Lawmakers originally created conservatorships to protect especially vulnerable individuals from abuse and exploitation. A 2013 American Association of Retired Persons (AARP) report estimated that 1.5 million adults in the US are under a guardianship or conservatorship, with seniors making up the largest share of conservatees.[73].

As the population in California continues to age, conservatorships are becoming more common. For example, a 2021 ABC News investigation found that in California alone just under 13 billion dollars are under the supervision and control of conservatorships.[74] Additionally, these laws can disrupt a person’s individual freedom with very little oversight from regulators, which can create a situation ripe for conservator abuse.[75] For example, Linda Duncan and her husband lived in a single-story home in Camarillo.[76] After her husband passed away, Duncan was forced, against her wishes, to enter into a conservatorship.[77] She was eventually placed in an assisted living facility in Auburn, Alabama, hundreds of miles from her home.[78] Her daughter does not believe that she belongs there.[79] Instead, her daughter believes Duncan should be living at the home that her husband set up for her retirement. [80] This industry grows as the population ages. It is estimated that by 2035, California will have more 65-year-olds than 18-year-olds.[81]

The California Probate Code defines a conservator as a person who may be appointed to provide assistance for a person that is “unable to provide properly for his or her personal needs for physical health, food, clothing, or shelter” and unable to manage their “own financial resources or resist fraud or undue influence.”[82] At first glance, a conservatorship arrangement appears to be beneficial to both the family and the conservatee. Families want to protect their loved ones and have peace of mind that they will be safe. Meanwhile, conservatees can continue to live their lives, albeit with help from a loved one or court-appointed conservator. There are positives and negatives to the legal arrangement as applied to celebrities and the public alike. \

One of the biggest benefits of a court-appointed conservatorship is that the conservator is subject to court supervision and control.[83] Additionally, conservatorships can give family members comfort in knowing that someone is taking care of an incapacitated loved one.[84] Family members may take solace in the fact that someone with full cognitive abilities is making decisions, preventing financial abuse and providing clear legal authority to deal with third parties, all within a process that requires judicial approval of major choices.[85] This may relieve stress for family members and create peace of mind.[86]

Meanwhile, some experts argue that a conservatorship provides a high degree of protection when compared to other options such as a power of attorney or living trusts.[87] It provides a structured method to help someone who is incapacitated and may be unwilling to accept assistance. Also, the supervision creates more protections for the conservatee than would normally be available.[88] For example, an important medical decision like a life-saving treatment would require court permission. Also, a conservatorship can also provide a mechanism to minimize the mismanagement of funds.[89]

Drawbacks to conservatorships include the expenses required to set one up. These expenses can include consulting a lawyer, filing legal papers and attending court hearings.[90] Also, the process can be time consuming and emotionally difficult for both the conservator and the family members who disagree about key issues such as whether a conservatorship is the right option or who the conservator should be.[91] Additionally, there are opportunities for people to take advantage through conservatorship abuse, like the kind Britney alleged.

Conservatorship Abuse

Britney’s claims about her conservatorship illustrate the dark side of conservatorships and what many experts fear when it comes to the huge amount of power that conservators have over conservatees.

One of the biggest problems with conservatorships is that they strip people of their legal rights, including the right to challenge the conservatorship itself.[92] A conservatee cannot hire an attorney without permission from the court to do so.[93] Conservatees also lack standing to bring suits on their own.[94] During the life of a conservatee, the conservator and only the conservator has standing.[95] Victims of conservatorship abuse lack the legal ability to escape this arrangement.[96] It is one of the reasons why many conservatorships survive until the death of the conservatee.[97]

A 2018 study conducted by the National Center for State Courts analyzed 31 cases of financial exploitation at the hands of conservators.[98] Its findings were alarming: many of the instances of financial exploitation occurred within the family, and the victims were mostly women.[99] Meanwhile, a 2010 study from the United States Government Accountability Office (GAO) identified hundreds of allegations of physical abuse, financial exploitation and neglect by guardians between the years 1990 and 2010.[100] The GAO found that guardians stole or otherwise improperly obtained millions of dollars in assets from hundreds of incapacitated victims, many of them seniors.[101]

While conservatorships provide an opportunity for calculating individuals to take advantage of conservatees, getting rid of conservatorships may not be an option: there still needs to be a system in place to help people who cannot take care of themselves. Conservatorships were originally created to protect some of society’s most vulnerable from abuse, financial or otherwise. However, this system now may be doing more harm than good, as it deprives conservatees a meaningful opportunity to challenge their status. For this reason, there has been growing political momentum to change the laws governing conservatorships and make it more difficult for conservators to have unlimited and often unchecked control over conservatees.

Future of Conservatorships

In recent months, conservatorships and adult guardian laws have been rapidly changing, which will affect future dynamics between conservators and conservatees. Several states––including California, where Britney’s conservatorship was created––have successfully enacted new legislation to impose more burdens on conservators in the hopes of preventing abuse.[102] On September 30, 2021, California Governor Gavin Newsom signed AB 1194, nicknamed the #FreeBritney Bill, into law.[103] The bill enjoyed widespread bipartisan support.[104] The law aims to prevent a conservator from acting in a predatory fashion, like Jamie Spears allegedly did.[105] Among other things, the law imposes financial penalties on conservators who abuse conservatees and makes it easier for conservatees to remove conservators.[106]

Independent government agencies are also working on ways to enhance the rights of conservatees. On March 22, 2018, the National Council on Disability (NCD) published a two-hundred-page document titled “Beyond Guardianship: Toward Alternatives That Promote Greater Self-Determination.” The NCD found a lack of data on existing conservatorships and recommended initiatives to “produce effective and comprehensive data on guardianships.”[107] Some suggestions include having relevant government agencies collect data on whether or not the individuals they serve are subject to guardianship and the Department of Justice issuing guidance to states on their legal obligations.[108] Other recommendations include providing grants to researchers to try to better understand how a variety of conditions impact the ability of potential conservatees to make and implement decisions.[109]

Meanwhile, in recent years federal lawmakers in both the House and Senate have proposed separate legislation in response to Britney’s battle. In June 2021, the House introduced H.R. 4545, also known as the Free Britney Act, to “protect the rights of legally incompetent adults who are subject of a legal guardianship or conservatorship.”[110] Among other things, the Act would give conservatees the right to replace a private conservator with a public conservator without having to prove abuse.[111] It would also guarantee anyone under a conservatorship an independent caseworker to look for any signs of abuse.[112] This Act has been referred to the House Committee on the Judiciary.[113]

In 2019, the Senate introduced the Guardianship Accountability Act, which would create a National Online Resource Center on Guardianship for the publication of both “resources and data relating to court-determined adult guardianships.”[114] The resource center would provide public information to help states develop better practices and give federal grant money for both background checks and training of potential guardians.[115]

Alternatives to Conservatorship

In 2021, Spears gave a passionate 23-minute statement to Judge Penny while fans protesting her conservatorship gathered outside the courthouse. In her statement, Spears described feeling exploited, bullied and “left out and alone” due to her conservatorship.[116] Britney explained to the judge that she just wanted her life back and “it’s enough and it makes no sense at all.”[117]

So, what are the alternatives to conservatorships? There are a few viable alternatives that could be implemented immediately: power of attorney, a trust and a health care representative. 

Power of Attorney 

The first alternative, the power of attorney, allows a person, called the principal, to give another person, the attorney-in-fact, authority to act on the principal’s behalf.[118] This gives a principal who could have been subject to a conservatorship more power than they would have had under a conservatorship because a court decides the level of the attorney-in-fact’s authority.[119] Additionally, the principal can decide who their attorney-in-fact will be instead of the court.[120] This is in contrast to conservatorships, where the judge has discretion over whether to approve a conservatorship and who to appoint as the conservator.[121] In Britney’s case, this would have enabled her to decide who to appoint as her attorney-in-fact and what powers to give them—instead, the legal system made these crucial decisions for her.

Trust

A trust could also be a good alternative to a conservatorship. The main difference between a conservatorship and a trust is that a trustee only has authority over the assets held by the trust, whereas conservators can have complete access to all of a conservatee’s assets.[122] This could have kept the majority of Britney’s assets safe, addressing some of the Spears family’s original concerns about the singer’s manager allegedly improperly taking her money. Simultaneously, it would have provided Britney with some control over her more day-to-day expenses.

Health Care Representative

Finally, an advance health care directive would allow a health care representative to make medical decisions—and only medical decisions—for a principal. The health care representative does not make any choices about any other aspects of the principal’s life, including financial decisions.[123] This could have been a good option for Britney, as she was placed under a conservatorship precisely because of concerns about her mental health. A health care representative could have enrolled Britney in counseling or provided other mental health services to help her work through the emotional aspects of her divorce and custody losses. If Britney had done well, she may have even been able to regain partial or full custody of her children.  

In addition to these more formal alternatives to conservatorships, there are also local services that provide help for people. In Los Angeles there are many agencies that help people with special needs. These agencies provide individuals with cases managers who can help them determine which programs and services may be beneficial.[124] Although these small agencies may be unequipped to assist someone with Britney’s enormous wealth and star power, they can provide real help to the vast majority of individuals subjected to conservatorships. Finally, adults in need can always set up a joint banking account with someone they trust to handle their financial matters.

All of these alternatives provide would-be conservatees with more agency than they would have in conservatorships. Britney certainly could have benefitted from more informal measures, at least at the outset of her troubles, to try to address the challenges she faced before being subjected to the control of a conservatorship

Conclusion

Britney’s allegations are an example of what could go wrong in Hollywood when some of the people closest to rising stars want to take advantage of them. Although there are reform efforts developing alongside public outcry for more oversight, meaningful change may be slow given the limited resources of the government and the large number of people under conservatorships.

Meanwhile, as Britney, Bynes and other Hollywood celebrities have gained their freedom and independence from conservatorships, there is a new generation of young stars who could be subjected to abuse. Whether through legal options, like conservatorships and guardianships, or outright theft of their budding fortunes before they have access to them, young stars are particularly vulnerable to financial abuse.[125] To prevent this, lawmakers and courts must provide new policies and additional oversight—or else this, well, “toxic” system will continue.

About the author

Emily Weisberg (’24) grew up in Calabasas, California. She obtained her bachelor's degree at UC Berkeley in 2019 with a degree in Political Science with an emphasis in International Relations. She has prior entertainment experience at NBCUniversal and KNBC Channel 4 News. At USC Gould, Emily was Treasurer of the Entertainment Law Society and Administration Chair of the Sports Law Society. This fall, Emily will study abroad in Lyon, France and serve as an articles editor for the Southern California Interdisciplinary Law Journal. This summer, Emily will work at Abrams Media.

[1] #FreeBritney END THE CONSERVATORSHIP, change.org, (last visited: Oct. 5, 2022), https://www.change.org/p/freebritney-2.

[2] Mason Bissada, Britney Spears’ Conservatorship Terminated After 13 Years, Forbes (Nov. 12, 2021), https://www.forbes.com/sites/masonbissada/2021/11/12/britney-spears-conservatorship-terminated-after-13-years/?sh=e1898897ea88.

[3] Id.

[4] Stacy Barrett, How the Britney Spears Case Might Change Conservatorship Law Forever, NOLO (Nov. 12, 2021), https://www.nolo.com/news/how-the-britney-spears-case-might-change-conservatorship-law-forever.html.

[5]Id.

[6] Eliza Thompson, Amanda Bynes’ Conservatorship Terminated After Nearly 9 Years, US Magazine (Mar. 22, 2022), https://www.usmagazine.com/celebrity-news/news/amanda-bynes-conservatorship-ends-after-nearly-9-years/.

[7] Eric Reed, What is a Conservatorship and How Does It Work?, Smart Asset (Sep. 1, 2022), https://smartasset.com/financial-advisor/what-is-conservatorship.

[8] Lawrence Friedman and Mark Savage, Article, Taking Care: The Law of Conservatorships in California, 61 S. Cal. L. Rev. 273 (Jan. 1988).

[9] Self-Help Probate Conservatorship, The Superior Court of California Santa Clara, (last visited Sep. 15, 2022), https://www.scscourt.org/self_help/probate/conservatorship/conservatorship_home.shtml.

[10] Friedman, supra note 8.

[11] Id.

[12] Id.

[13] Id.

[14] Id.

[15] Id.

[16] Katz v. Superior Court, 73 Cal App. 3d 952, 963 (Cal. App. Dep’t Super. Ct. 1977).

[17] California Mental Health Act of 1967, ch 1667, sec. 36, §§ 5350-5368, 1967 Cal. Stat. 4074, 4093-98 (codified as amended at CAL. WELF. & INST. CODE §§ 5350-5371 (West 1981 & Supp. 1987).

[18] Disability Rts. Cal., Understanding the Lanterman-Petris-Short (LPS) Act (Jan. 8, 2018), https://www.disabilityrightsca.org/publications/understanding-the-lanterman-petris-short-lps-act.

[19] LPS (Mental Health) Conservatorship, Superior Court of California County of Santa Clara (last visited: Nov. 19, 2022), https://scscourt.org/self_help/probate/conservatorship/conseravtorhsip_lps.shtml.  

[20] Supra, note 8.

[21] Id.

[22] Limited Conservatorship, Superior Court of California County of Santa Clara, (last visited: Nov. 20, 2022), https://www.scscourt.org/self_help/probate/conservatorship/conservatorship_limited.shtml#what.

[23] The Difference Between General & Limited Conservatorship, Keystone Law Group, P.C., (last visited: Dec. 3, 2022), https://keystone-law.com/general-v-limited-conservatorship.

[24] Conservatorship, California Courts The Judicial Branch of California, (last visited: Sep, 20, 2022), https://www.courts.ca.gov/selfhelp-conservatorship.htm?rdeLocaleAttr=en.

[25] Conservatorship, Superior Court of California County of San Diego, (last visited: Oct. 28, 2022), https://www.sdcourt.ca.gov/sdcourt/probate2/conservatorship.

[26] Self-help information sheet Probate Conservatorship, Superior Court of California, (last visited: Dec. 3, 2022), https://www.courts.ca.gov/partners/documents/SHInfo-ConservatorshipOCAug2017.pdf. 

[27] Id.

[28]Conservatorship, Superior Court of California County of San Bernardino, (last visited: Dec. 3, 2022), https://www.sb-court.org/divisions/probate/conservatorship.

[29] Britney’s Father, Jamie Spears, has been immediately suspended as her conservator, Cosmopolitan, (Sep. 30, 2021), https://www.cosmopolitan.com/uk/reports/a33333300/free-britney/.

[30] Ashley Cullins, Britney Spears; Father Sues Blogger for Defamaation Over #FreeBritney-Related Allegations, Hollywood Reporter (June 26, 2019), https://www.hollywoodreporter.com/business/business-news/britney-spears-father-sues-freebritney-blogger-defamation-1221212/.

[31] Id.

[32]Liz Day, Britney Spears Fights Father’s Fee Claim, Alleging Financial Misconduct, N.Y. Times (Jan. 18, 2022), https://www.nytimes.com/2022/01/18/business/britney-spears-father-fees.html; see also Tessa Sturart, Can Britney Spears’ Conservators Legally Bar Her From Having a Baby?, Rolling Stone (June 25, 2021), https://rollingstone.com.music/music-news-britney-spears-conservators-baby-marriage-rights-1188207/.

[33] Debanjali Bose, Britney Spears’ father denies having any involvement in her ‘personal affairs’ after her bombshell testimony alleging she’s forced to have an IUD and can’t get married, Insider (Jun. 30, 2021), https://www.insider.com/jamie-spears-britney-spears-conservatorship-personal-affairs-2021-6: see also Britney Doha Madani and Wilson Wong, Spears’ father was suspended as a conservator. What’s next?, NBC News (Oct. 1, 2021), https://www.nbcnews.com/pop-culture/pop-culture-news/britney-spears-father-was-suspended-conservator-what-s-next-n1280603.

[34] Bre Williams, Why Did Britney Spears Divorce Kevin Federline?, Cheat Sheet (Mar. 28, 2020), https://www.cheatsheet.com/entertainment/why-did-britney-spears-divorce-kevin-federline.html/.

[35] Id.

[36] Id.

[37] Ronan Farrow and Jia Tolentino, American Chronicles Britney Spear’s Conservatorship Nightmare, How the pop star’s father and a team of lawyers seized control of her life– and have held on to it for thirteen years, The New Yorker (July 3, 2021), https://www.newyorker.com/news/american-chronicles/britney-spears-conservatorship-nightmare.

[38] Id.

[39] Id.

[40] Id.

[41] Caitlin Medcalf, Britney Spears’ Former Manager Sam Lutfi Admits He “Failed Her”, Musicfeeds (July 15, 2021), https://musicfeeds.com.au/news/britney-spears-ex-manager-sam-lutfi-admits-he-failed-her/; see also Debanjali Bose, Britney Spears’ former manager Sam Lutfi says the singer’s parents ‘have ruined both our lives’, Insider (July 15, 2021), https://www.insider.com/sam-lutfi-britney-spears-conservators-ruined-our-lives-2021-7.

[42] Supra, note 37.

[43] Id.

[44] Id.

[45] Id.

[46] Id.

[47] Id.

[48] Id.

[49] Id.

[50] Id.

[51] Joe Coscarelli et al., Britney Spears’s Courtroom Plea Spurs Questions for Her Lawyer, The New York Times (June 24, 2021), https://www.nyttimes.com/2021/06/24/arts/music/britney-spears-lawyer-samuel-ingham.html.

[52] Doha Madani & Diana Dasrath, Britney Spears’ professional co-conservator files to resign after explosive testimony, NBC News (July 1, 2021), https://www.nbcnews.com/pop-culture/pop-culture-news/britney-spears-professional-co-conservator-files-resign-after-explosive-testimony-n1272953.

[53] Samantha Schnurr, Britney Spears Calls Conservatorship “Voluntary” in Request for New Guardian of Her Estate, E! News(Sep. 2, 2020), https://www.eonline.com/news/1184508/britney-spears-calls-conservatorship-voluntary-in-request-for-new-guardian-of-her-estate.

[54] Cal. Prob. Code § 1810 (West, Westlaw through 2022 Reg. Sess.)

[55] Anastasia Tsiouclas, Britney Spears’ Conservatorship Has Finally Ended, NPR (Nov. 12, 2021), https://www.npr.org/2021/11/12/1054860726/britney-spears-conservatorship-ended.

[56] Id.

[57] Joe Coscarelli, Britney Spears: End Conservatorship, but Remove My Father First, N.Y. Times (Sep. 22, 2021), https://www.nytimes.com/2021/09/22/arts/music/britney-spears-jamie-conservatorship.html.

[58] Ashley Cullins, Britney Spears’ Capacity Called Into Question as Lawyer Defends Lack of Direct Testimony, The Hollywood Reporter (Oct. 8, 2020), https://www.hollywoodreporter.com/business/business-news/britney-spears-capacity-called-into-question-as-lawyer-defends-lack-of-direct-testimony-4073552/.

[59] Elizabeth Wagmeister, Britney Spears’ Court-Appointed Lawyer Resigns From Conservatorship Case, Variety (July 6, 2021), https://variety.com/2021/music/news/britney-spears-samuel-ingham-resign-conservatorship-1235012511/.

[60] Julia Jacobs, Who is the judge presiding over the conservatorship case?, N.Y. Times (Sep. 29, 2021), https://www.nytimes.com/live/2021/09/29/arts/britney-spears-conservatorship.

[61] Lisa Richwine, Britney Spears’ lawyer seeks to oust singer’s father from conservatorship, Reuters (July 26, 2021), https://www.reuters.com/lifestyle/britney-spears-lawyer-seeks-conservator-replace-singers-father-ny-times-2021-07-26/.

[62] Jill Serjeant, Britney Spears’ dad to relinquish control of her $60 mln estate, Reuters (Aug. 12, 2021), https://www.reuters.com/lifestyle/jamie-spears-agrees-step-down-daughter-britneys-conservator-attorney-2021-08-12/.

[63] Id.

[64] Joe Coscarelli and Julia Jacobs, Judge Ends Conservatorship Overseeing Britney Spears’s Life and Finances, N.Y. Times(Nov. 12, 2021), https://www.nytimes.com/2021/11/12/arts/music/britney-spears-conservatorship-ends.html.

[65] Id.

[66] Celebrities Who’ve Had Conservatorships, TooFab (Dec. 29, 2021), https:www.toofab.com/2021/12/29/celebrities-who-had-conservatorships/.

[67] Morgan Greenwald, Britney Spears, Joni Mitchell & 5 More Entertainers Once Ruled by a Conservatorship, Billboard (May 5, 2016), https://www.billboard.com/music/music-news/ritney-spears-joni-mitchell-conservatorship-7357836/.

[68] Doha Madani and Diana Dasrath, Amanda Bynes conservatorship terminated nearly 9 years, NBC News (Mar. 22, 2022), https://www.nbcnews.com/pop-culture/pop-culture-news/amanda-bynes-conservatorhsip-expeced--end-judges-tentative-ruling-rcna17979.    

[69] Id.

[70] Supra, note 66.

[71] Id.

[72] Id.

[73] Emily Gurnon and SCAN Foundation, Guardianship in the U.S.: Protection or Exploitation, Next Avenue (May 23, 2016), https://www.nextavenue.org/guardianship-u-s-protection-exploitation/.

[74] Andie Judson, The Price of Care: Investigating California Conservatorships, ABC10 (last updated: May 31, 2021), https://www.abc10.com/article/news/local/abc10-originals/investigating-california-conservatorships-the-price-of-care-series/103-a0593dd2-f00c-4fc6-93e8-7e0f6912b4bb.

[75] Id.

[76] Id.

[77] Id.

[78] Id.

[79] Id.

[80] Id.

[81] Id.

[82] Cal. Prob. Code § 1801 (West, Westlaw through 2022 Reg. Sess.)

[83] What are the Advantages and Disadvantages of a Conservatorship?, Schomer Law Group, APC (Apr. 20, 2014), https://www.schomerlawgroup.com/general/advantages-disadvantages-conservatorship/.

[84] Adult Guardianship, Caring.com (last visited: Oct. 5, 2022), https://www.caring.com/caregivers/adult-guardianship/. 

[85] Id.

[86] Id.

[87] Conservatorship and Partnership, Family Caregiver Alliance (Iast visited: Nov. 4, 2022), https://www.caregiver.org/resource/conservatorship-and-guardianship/.  

[88] Pros and Cons of a Conservatorship in California, Schomer Law Group, APC (last visited: Nov. 3, 2022) https://www.schomerlawgroup.com/elder-law/pros-cons-conservatorship-california/.  

[89] Id.

[90] Supra, note 87.

[91] Id.

[92] Chandra Bozelko, Britney Spears’ conservatorship can be both totally legal and quite bad for her. Many are., NBC News(Nov. 14, 2020), https://www.nbcnews.com/think/opinion/britney-spears-conservatorship-can-be -both-totally-legal-quite-bad-ncna1247750.       

[93] Id.

[94] Id.

[95] Id.

[96] Id.

[97] Id.

[98] National Center for State Courts, Conservatorship Exploitation in Minnesota: An Analysis of Judicial Response, Elders and Courts- (2018), https://www.eldersandcourts.org/__data/assets/pdf_file/0019/5833/ovc-brief-2.pdf.

[99] Id.

[100] GAO-10-1046, Guardianships: Cases of Financial Exploitation, Neglect, and Abuse of Seniors, U.S. Gov’t Accountability Off.(2010), https://www.gao.gov/assets/gao-10-1046.pdf. 

[101] Id.

[102] William C. Sias and Peter Stern, Webinar: AB 1994: New Burdens for Conservators, CA Lawyers (Dec. 15, 2021), https://calawyers.org/event/webinar-ab-1194-new-burdens-for-conservators/.

[103] AB 1194, Openstates, https://openstates.org/ca/bills/20212022/AB1194/.

[104] Id.

[105] Id.

[106] Id.

[107] National Council on Disability, Beyond Guardianship: Towards Alternatives That Promote Greater Self-Determination (2018), https://ncd.gov/sites/default/files/NCD_Guardianship_Report_Accessible.pdf.

[108] Id.

[109] Id.

[110] Free Britney Act, H.R., 117th Cong. (2021), https://files.constantcontact.com/e77991c4801/2d2264a2-3edf-4692-80e9-bff63bb9cc4e.pdf.

[111] Id.

[112] Id.

[113] H.R.4545 – Freedom and Right to Emancipate from Exploitation (FREE) Act, Congress.gov, (last visited: Nov. 20, 2022), https://www.congress.gov/bill/117th-congress/house-bill/4545.  

[114] Guardianship Accountability Act of 2019, S. 591, 116th Cong. (2019), https://www.congress.gov/bill/116th-congress/senate-bill/591.

[115] Id.

[116] Read Britney Spears’ Statement to the Court In Her Conservatorship Hearing, NPR (June 24, 2021), https://www.npr.org/2021/06/24/1009858617/britney-spears-transcript-court-hearing-conservatorship.

[117] Id.

[118]  Adam Hayes, What Is an Attorney-in-Fact?, Investopedia, (Aug. 30, 2022), https://www.investopedia.com/terms/a/attorneyinfact.asp.

[119] Power of Attorney, ABA, (last visited: Dec. 2, 2022), https://www.americanbar.org/groups/real_property_trust_estate)resources/estate_planning/power_of_attorney/.

[120] Id.

[121]  Conservatorship v. Power of Attorney and Other Alternatives to Conservatorship Explained, Keystone Law Group (Oct. 5, 2022), P.C., https://keystone-law.com/conservatorship-vs-power-of-attorney.

[122] Id.

[123] Id.

[124] Alternatives to Conservatorship In California, Schomer Law Group, APC. (Nov. 6, 2015), https://www.schomerlawgroup.com/article/alternatives-conservatorship-california/.

[125] See Destiny Lopez, 7 Celebs Whose Parents Decimated Their Fortunes, Insider (Apr. 2, 2014), https://www.businessinsider.com/7-celebs-whose-parents-decimated-their-fortunes-2014-4 (showing seven celebrities who made a lot of money as child stars who had their parents squander their fortunes including Macaulay Culkin, Jackie Coogan, Shirley Temple, Mimi Gibson, Gary Coleman, Leann Rimes, and Dominique Moceanu).