Filed Date: April 4, 2019
Closed Date: May 24, 2019
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This case concerns the ability of a protection and advocacy agency (P&A) to obtain records necessary to investigate alleged abuse and neglect of hospitalized patients with mental illness. A state P&A agency filed a case in federal court to obtain access to these records.
Plaintiff Disability Rights California (“DRC”) filed its complaint on April 4, 2019, in the U.S. District Court for the Northern District of California. After a reassignment, the case was presided over by Judge Yvonne Gonzalez Rogers. Disability Rights California was represented in this matter by itself. The defendants, Alan Yamamoto, the Director of San Benito County Behavioral Health (sued in his official capacity), and the County of San Benito were represented in this matter by Hooper, Lundy & Bookman, P.C.
The suit sought to stop the County of San Benito and its County mental health agency from denying DRC access to witnesses and records. These were needed to carry out an investigation into abuse and neglect of patients with mental illness who are held in the emergency room of a local medical facility, Hazel Hawkins Hospital.
DRC brought the claims on its own behalf under the Protection and Advocacy for Individuals with Mental Illness Act (hereinafter “PAIMI”), 42 U.S.C. § 10801, et seq. and under 42 U.S.C. § 1983. The PAIMI Act provides Plaintiff DRC with the right, duty and authority to investigate incidents of abuse and neglect of individuals with disabilities, including those with mental illness.
Per the complaint, DRC had received reports that Defendants routinely detained county residents who were in psychiatric crisis in the emergency room of Hazel Hawkins Hospital for excessive periods of time, without providing them with access to appropriate mental health treatment and potentially in violation of due process requirements. DRC made a finding of probable cause to believe that the abuse and neglect of County patients had occurred, which should have permitted them access to these records through its investigations authority. DRC repeatedly requested access to this information, but defendants refused to provide it. Specifically, DRC sought the names and contact information of psychiatric patients held involuntarily at Hazel Hawkins Hospital for more than twenty-four hours.
On April 3, 2019, Defendants’ counsel informed DRC that Defendants would not comply with the request absent a court order. As a result, DRC filed suit the following day seeking the following relief: 1) a declaratory judgment that Defendants violated federal law; 2) injunctive relief requiring Defendants to provide access to all information required for a full investigation and forbidding Defendants from interfering with DRC's statutorily authorized access to information, consistent with federal and state law.
On April 3,2019, counsel for the County filed a case against DRC in state court for declaratory relief, seeking “a judicial determination of [the County’s] duty to disclose confidential patient information.” On April 8, 2019, DRC filed a Motion For Preliminary Injunction. In it, DRC requested that the Court issue a preliminary injunction granting it access to the information described above.
On May 20, 2019, the parties filed a joint motion and stipulation as follows: That 1) Defendants were ordered to provide DRC with the names and contact information of individuals held for more than twenty four (24) hours at Hazel Hawkins Hospital from January 1, 2018 through December 31, 2018, within five business days of the order and on a rolling basis going forward, 2) Defendants were ordered to provide DRC all further access to which DRC is entitled pursuant to statutory authority; 3) the parties agree to dismiss State Court Action; 4) Plaintiff’s Motion for Preliminary Injunction will be removed from the court calendar; and, 6) Defendants will pay to DRC attorneys’ fees and costs. This stipulation and resulting order brought the case to a close.
Summary Authors
NDRN (4/22/2025)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/14881549/parties/disability-rights-california-v-county-of-san-benito/
Bird, Melinda Ruth (California)
Fischer, Aaron Joseph (California)
Hadreas, Anne Catherine (California)
Chan, Eric David (California)
Lin, Sansan (California)
See docket on RECAP: https://www.courtlistener.com/docket/14881549/disability-rights-california-v-county-of-san-benito/
Last updated Aug. 6, 2025, 10:30 p.m.
State / Territory: California
Case Type(s):
Healthcare Access and Reproductive Issues
Key Dates
Filing Date: April 4, 2019
Closing Date: May 24, 2019
Case Ongoing: No
Plaintiffs
Plaintiff Description:
P&A as organizational plaintiff
Plaintiff Type(s):
Non-profit NON-religious organization
Attorney Organizations:
NDRN/Protection & Advocacy Organizations
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Case Details
Causes of Action:
Protection and Advocacy for Individuals with Mental Illness (PAIMI) Act, 42 U.S.C. § 10801
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Issues
Disability and Disability Rights: