Disability Rights California v. County of Alameda

CourtDistrict Court, N.D. California
DecidedJanuary 21, 2021
Docket3:20-cv-05256
StatusUnknown

This text of Disability Rights California v. County of Alameda (Disability Rights California v. County of Alameda) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Disability Rights California v. County of Alameda, (N.D. Cal. 2021).

Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 DISABILITY RIGHTS CALIFORNIA, Case No. 20-cv-05256-CRB

9 Plaintiff, ORDER GRANTING MOTIONS TO 10 v. DISMISS AND DENYING MOTION TO STRIKE 11 COUNTY OF ALAMEDA, et al., 12 Defendants.

13 Disability Rights California (DRC) is suing the County of Alameda (the County), 14 Alameda County Behavioral Health Care Services (ACBHCS), and Alameda Health 15 System (AHS) for alleged violations of the Americans with Disabilities Act, the 16 Rehabilitation Act, and California disability law. DRC alleges that Defendants subject 17 Alameda residents to unnecessary institutionalization and an unnecessary risk of 18 institutionalization by failing to provide sufficient community-based treatment programs 19 and other services that would reduce institutionalization in the County. 20 AHS has moved to dismiss DRC’s claims for lack of standing and for failure to 21 state a claim for which relief may be granted. Separately, the County and ACBHCS 22 (collectively, the County Defendants) have moved to dismiss DRC’s claims for lack of 23 standing and for failure to state a claim for which relief may be granted. 24 Although the Court concludes that DRC has standing, the Court grants Defendants’ 25 motions to dismiss with leave to amend because DRC has not stated a claim against AHS, 26 the County, or ACBHCS for which relief may be granted. The Court determines that there 27 is no need for oral argument. I. BACKGROUND 1 The Protection and Advocacy for Individuals with Mental Illness Act (PAIMI)’s 2 express statutory purpose is, in part, “to assist States to establish and operate a protection 3 and advocacy system for individuals with mental illness.” 42 U.S.C. § 10801(b)(2). A 4 Protection & Advocacy system established under PAIMI has authority to “pursue 5 administrative, legal, and other remedies” on behalf of state residents with mental 6 illnesses. Id. § 10805(a)(1)(C). California has designated DRC to serve as California’s 7 Protection & Advocacy system for people in California with disabilities. Id. ¶ 19. DRC 8 refers to California residents for whom it advocates as “Constituents.” Id. ¶ 23. 9 On July 30, 2020, DRC brought this action against the County, ACBHCS, and 10 AHS. Complaint (dkt. 1) ¶ 1. ACBHCS is a County entity that implements the County’s 11 mental health system and provides mental health services to County residents. Id. ¶¶ 51, 12 66. AHS owns and operates John George Psychiatric Hospital (John George), where it 13 provides inpatient care under a contract with ACBHCS, but not Villa Fairmont Mental 14 Health Rehabilitation Center (Villa Fairmont), another County psychiatric institution 15 located on the same “campus” as John George. Id. ¶¶ 3, 6, 52, 66, 107. 16 A. General Allegations 17 DRC opened an investigation into the County’s institutionalization practices in 18 2018. Id. ¶ 69. The investigation involved touring mental health facilities, Santa Rita Jail, 19 and various homeless shelters and interviewing their residents. Id. On November 1, 2019, 20 DRC “found probable cause to believe” that the County had abused and neglected DRC 21 Constituents based on Defendants’ failure to provide “needed services and support in the 22 most integrated setting appropriate.” Id. ¶ 70. Here, the relevant DRC Constituents are 23 “adult Alameda County residents” who “have a serious mental health disability” and 24 whom DRC alleges “are unnecessarily segregated in the County’s psychiatric institutions 25 or are at serious risk of being needlessly segregated into these institutions.” Id. ¶¶ 23–24. 26 DRC has listed several individual Constituents as exemplars. Id. ¶ 28. 27 In general, DRC alleges that “Defendants have not provided sufficient intensive 1 community-based mental health services to DRC Constituents, and are causing them, 2 particularly black DRC Constituents, to be unnecessarily segregated in costly, publicly 3 funded institutions, often repeatedly.” Id. ¶ 71. DRC alleges that Defendants’ practices 4 violate federal and state laws prohibiting unnecessary institutionalization, and that 5 Defendants can reasonably accommodate providing expanded “community-based” or 6 “integrated” services. Id. ¶¶ 54–63.1 7 Based on these general allegations, DRC seeks a declaratory judgment that 8 Defendants are violating the Americans with Disabilities Act (ADA), the Rehabilitation 9 Act, and California Government Code sections 11135 and 11139. Id. at 38–39. DRC also 10 seeks an injunction requiring Defendants to comply with these laws. Id. at 39. 11 B. Specific Allegations 12 1. Unnecessary Institutionalization 13 DRC alleges that Defendants “unnecessarily segregate DRC Constituents into 14 psychiatric institutions.” Id. at 17. Under California law, if County staff state that they 15 have reason to believe that a person is gravely disabled or a danger to themselves or others 16 due to a mental health disability, the County can detain the person for 72 hours. Id. ¶ 72 17 (citing Cal. Welf. & Inst. Code § 5150(a)). DRC alleges that the County detains more 18 individuals than any other county in California, at more than triple the statewide rate. Id. 19 ¶ 73. As DRC puts it, “[b]ecause Defendants’ community-based services are insufficiently 20 available, the County detains vast numbers of DRC Constituents in crisis at John George, 21 the designated public hospital authority . . . . The psychiatric hospital is large, crowded, 22 and physically isolated from community life.” Id. ¶¶ 74–75. 23 Part of the alleged unnecessary institutionalization takes place in John George’s 24

25 1 DRC alleges that “Defendants’ practices place DRC constituents at especially grave risk from the COVID-19 pandemic” because, although they have initiated social distancing protocols, “there 26 remains a significant risk of Covid-19 infection spreading through” Defendants’ facilities. Complaint ¶¶ 141, 143. “Given the grave risk of infection for DRC Constituents who cycle 27 between jail, John George, Villa Fairmont, and homelessness, DRC constituents need intensive 1 Psychiatric Emergency Services (PES) unit. Plaintiffs allege that the County detains 2 “nearly 1,000 people at John George’s PES unit every month,” that 36% of those detained 3 are black, that black men are 30% more likely to be detained after a mental health crisis 4 call, and that “[a]ccording to the County’s own estimates, more than 75% of those detained 5 in PES do not meet medical necessity criteria for inpatient psychiatric services.” Id. 6 ¶¶ 77–79. At PES, detainees are locked in a 35x45 foot “filthy” room, “where they must 7 compete for places to sit, lie, or stand.” Id. at ¶ 80. These conditions “often exacerbate 8 rather than alleviate people’s mental health symptoms.” Id. “Many DRC Constituents 9 spend fewer than twenty-four hours at the PES” before being released or transferred to one 10 of John George’s inpatient units or another facility, “but a significant number remain for 11 multiple days,” and some stay “for more than a week.” Id. ¶ 81. Because most are 12 released “without adequate intensive community-based services in place,” repeated “re- 13 institutionalization” is common. Id. ¶ 82. 14 Additional alleged unnecessary institutionalization takes place in John George’s 15 inpatient units. Id. at 19. About 25% of people brought to PEC are admitted to these units, 16 which are “highly institutional settings” with “locked wards” that are “monitored 17 continuously” and subject to “rigid rules.” Id. ¶ 83.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Warth v. Seldin
422 U.S. 490 (Supreme Court, 1975)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Olmstead v. L.C.
527 U.S. 581 (Supreme Court, 1999)
Tellabs, Inc. v. Makor Issues & Rights, Ltd.
551 U.S. 308 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
M.R. v. Dreyfus
663 F.3d 1100 (Ninth Circuit, 2011)
M.R. v. Dreyfus
697 F.3d 706 (Ninth Circuit, 2011)
United States v. Donald R. Bennett, Also Known as Butch
332 F.3d 1094 (Seventh Circuit, 2003)
Arc of Washington State Inc. v. Braddock
427 F.3d 615 (Ninth Circuit, 2005)
Leadsinger, Inc. v. BMG Music Publishing
512 F.3d 522 (Ninth Circuit, 2008)
National Council of La Raza v. Barbara Cegavske
800 F.3d 1032 (Ninth Circuit, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Disability Rights California v. County of Alameda, Counsel Stack Legal Research, https://law.counselstack.com/opinion/disability-rights-california-v-county-of-alameda-cand-2021.