Is a family court order requiring a father to submit to involuntary psychotherapy a violation of his due process?

More recently, in Camacho v. Camacho, supra, the court applied Marriage of Matthews to hold that a family court order requiring a father to submit to involuntary psychotherapy as a condition on his custody rights was a direct violation of due process, "as it constitutes a fundamental restriction of his liberty unaccompanied by any procedural safeguards." (173 Cal.App.3d at pp. 221-222, 218 Cal.Rptr. 810.) In its due process analysis, the court was obviously troubled by the absence of any standards and findings, such as those required by the Lanterman-Petris-Short Act ( 5150 et seq. [civil commitment statute] ), on which to base a determination that the parent could be subjected to involuntary psychiatric treatment. The court was also concerned that there was no time limit on the court's order. (173 Cal.App.3d at p. 221, 218 Cal.Rptr. 810.)