I'm not sure I understand your question @greenjeanie. TurboTax will not let you e-file unless all the forms are final.
The e-filing process will not simply hold back the pending forms because each form may impact the numbers on other forms.
That said, since Form 3801 is a state form, you can e-file your federal return (assuming all those forms are final) and e-file California after Form 3801 is final.
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