University of Michigan Law School
Civil Rights Litigation Clearinghouse
new search
view search results
page permalink
Case Name Sonnenberg v. Disability Rights Idaho, Inc. MH-ID-0003
Docket / Court 1:14-cv-00369-EJL ( D. Idaho )
State/Territory Idaho
Case Type(s) Mental Health (Facility)
Special Collection DOJ Civil Rights Division Statements of Interest
Attorney Organization NDRN/Protection & Advocacy Organizations
U.S. Dept. of Justice Civil Rights Division
Case Summary
On August 29, 2014 Ada County and the Ada County Coroner filed a complaint in the Fourth Judicial District of Idaho. They sued Disability Rights Idaho (“DRI”) under Idaho Code § 10-1201 et seq., (Uniform Declaratory Judgment Act), and Idaho Rule of Civil Procedure 57. At the request of the ... read more >
On August 29, 2014 Ada County and the Ada County Coroner filed a complaint in the Fourth Judicial District of Idaho. They sued Disability Rights Idaho (“DRI”) under Idaho Code § 10-1201 et seq., (Uniform Declaratory Judgment Act), and Idaho Rule of Civil Procedure 57. At the request of the defendant, Disability Rights Idaho, Inc. (DRI), the case was removed to the United States District Court for the District of Idaho on September 8, 2014. On September 18, 2014 DRI filed a counterclaim under the Protection and Advocacy for Individuals with Mental Illness Act (PAIMI), 42 U.S.C. § 10801 et seq. and 42 U.S.C. § 1983. DRI sought injunctive and declaratory relief to challenge the refusal of the Coroner to provide timely access to the records sought. Ada County filed a motion to remand the case, but the motion was denied by Judge Edward J. Lodge on April 29, 2015. 2015 WL 1944003.

Disability Rights Idaho (DRI) is a non-profit corporation that has been designated by Idaho to protect and advocate on behalf of people with mental illness, as defined in the Protection and Advocacy for Individuals with Mental Illness Act of 1986, 42 U.S.C. § 10801 et. seq. (“PAIMI”). (PAIMI is a federal mandate that gives authority to investigate complaints of abuse, neglect, due process and rights violations in public and private facilities that provide overnight mental health treatment.) The dispute arose when the Ada County Coroner refused to provide its investigatory records relating to a suicide death of an individual, who had been residing in an inpatient behavioral health unit of an Ada County hospital. The Coroner denied DRI’s request for non-public records and initiated this declaratory judgment action in State court in response to DRI’s letter that stated they would initiate a federal lawsuit if necessary. DRI submitted an answer to the Coroner’s complaint and a counterclaim.

On June 15, 2015 both parties submitted Motions for Summary Judgment. In addition, DRI submitted a Motion to Dismiss and a Motion for Judgment on the Pleadings. The Ada County Coroner argued that regardless of PAIMI, DRI did not have the right to access the Coroner’s records of its death investigation, because the Coroner was not an “agency” as defined by PAIMI. The Coroner had also cited federal and state privacy concerns and questioned DRI’s probable cause to investigate the death. On July 20, 2015, the Department of Justice (DOJ) submitted a statement of interest stating that federal law was clear that P&A’s had broad access to investigatory records relating to mental health treatment facilities. The DOJ also stated that the Coroner’s office was an “agency charged with investigating,” as stated in PAIMI, because it was a division of the Ada County government that was responsible for investigating deaths.

On March 7, 2016, Judge Edward J. Lodge entered a judgment in favor of DRI. The court held that the Coroner was an “agency charged with investigating” reports of incidents of abuse, neglect, and injury under PAIMI and that the Coroner needed to release the records to DRI. 168 F.Supp.3d 1282. The case is now closed.

Mary Kate Sickel - 10/08/2017


compress summary

- click to show/hide ALL -
Issues and Causes of Action
click to show/hide detail
Issues
Content of Injunction
Required disclosure
Disability
disability, unspecified
Discrimination-basis
Disability (inc. reasonable accommodations)
General
Records Disclosure
Plaintiff Type
City/County Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Protection and Advocacy for Individuals with Mental Illness (PAIMI) Act, 42 U.S.C. § 10801
Defendant(s) Disability Rights Idaho, Inc.
Plaintiff Description Ada County Coroner and Ada County
Indexed Lawyer Organizations NDRN/Protection & Advocacy Organizations
U.S. Dept. of Justice Civil Rights Division
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief Declaratory Judgment
Injunction / Injunctive-like Settlement
Source of Relief Litigation
Case Closing Year 2016
Case Ongoing No
Additional Resources
click to show/hide detail
  Pierce County v. Washington
www.bazelon.org
Date: 2017
By: The Bazelon Center (The Bazelon Center)
[ Detail ] [ External Link ]

  Jane Doe v. Hunter College
http://www.bazelon.org/jane-doe-v-hunter-college/
Date: 2017
By: The Bazelon Center (The Bazelon Center)
[ Detail ] [ External Link ]

  Office of Protection and Advocacy v. State of Conneticut
http://www.bazelon.org/opa-v-ct/
Date: 2017
By: The Bazelon Center (The Bazelon Center)
[ Detail ] [ External Link ]

  From Hospitals to Prisons: A New Explanation
http://cornelllawreview.org/clronline/from-hospitals-to-prisons-a-new-explanation
Date: 2017
By: Fredrick E. Vars & Shelby B. Calambokidis (Cornell Law Review)
[ Detail ] [ External Link ]

Docket(s)
1:14−cv−00369−EJL (D. Idaho)
MH-ID-0003-9000.pdf | Detail
Date: 09/05/2014
Source: PACER [Public Access to Court Electronic Records]
General Documents
Complaint For Declaratory Relief [ECF# 1-3]
MH-ID-0003-0003.pdf | Detail
Date: 08/29/2014
Source: PACER [Public Access to Court Electronic Records]
Answer of Disability Rights Idaho Inc., to Complaint For Declaratory Relief Dated August 29, 2014 [ECF# 5]
MH-ID-0003-0004.pdf | Detail
Date: 09/18/2014
Source: PACER [Public Access to Court Electronic Records]
Memorandum Decision and Order [ECF# 24] (2015 WL 1944003) (D. Idaho)
MH-ID-0003-0005.pdf | WESTLAW | Detail
Date: 04/29/2015
Source: PACER [Public Access to Court Electronic Records]
Department of Justice Statement of Interest [ECF# 40]
MH-ID-0003-0001.pdf | External Link | Detail
Date: 07/20/2015
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Memorandum and Order [ECF# 42] (168 F.Supp.3d 1282) (D. Idaho)
MH-ID-0003-0002.pdf | WESTLAW| LEXIS | External Link | Detail
Date: 03/07/2016
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Judges Lodge, Edward J. (D. Idaho)
MH-ID-0003-0002 | MH-ID-0003-0005 | MH-ID-0003-9000
Plaintiff's Lawyers Coe, Cynthia (District of Columbia)
MH-ID-0003-0001
England, Christine G. (Idaho)
MH-ID-0003-0001
Gupta, Vanita (District of Columbia)
MH-ID-0003-0001
Hill, Eve L. (District of Columbia)
MH-ID-0003-0001
Morgan, Sherry A. (Idaho)
MH-ID-0003-9000
Olson, Wendy J. (Idaho)
MH-ID-0003-0001
Petty, Gene A (Idaho)
MH-ID-0003-0003 | MH-ID-0003-9000
Preston, Judy C. (District of Columbia)
MH-ID-0003-0001
Rush, Regan (District of Columbia)
MH-ID-0003-0001
Schultz, William B (District of Columbia)
MH-ID-0003-0001
Defendant's Lawyers Cunningham, Amy (Idaho)
MH-ID-0003-9000
Hummel, John C (Idaho)
MH-ID-0003-0004 | MH-ID-0003-9000
Other Lawyers Holthus, Courtney Rose (Idaho)
MH-ID-0003-9000

- click to show/hide ALL -

new search
view search results
page permalink

- top of page -