Filed Date: May 14, 2004
Closed Date: May 10, 2005
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This is a case regarding a protection and advocacy agency's (P&A) access to individual records and a facility-wide restraint and seclusion log under its records access authority. On May 14, 2004, Ohio Legal Rights Service (OLRS), Ohio’s P&A, filed this lawsuit in the U.S. District Court for the Southern District of Ohio. OLRS filed this lawsuit against Buckeye Ranch, a youth residential mental health facility, under the Protection and Advocacy for Individuals With Mental Illness (PAIMI) Act and Ohio state law. Represented by itself, OLRS sought injunctive relief that would require Buckeye Ranch provide them with records concerning an individual facility resident and facility-wide restraint and seclusion incident logs under the PAIMI Act and state law. Judge James. L. Graham presided over this matter.
This case began after OLRS reviewed media publications about Buckeye Ranch and received an incident report concerning of an individual Buckeye Ranch resident. Buckeye Ranch refused to provide OLRS with the individual’s records and provided limited information in the restraint and seclusion logs. In April 2005, the court reviewed OLRS’s claims under both the PAIMI Act and state law. Under the PAIMI Act, the court deferred ruling on the individual’s records for supplemental briefs on the individual’s guardianship status until both parties filed supplemental briefings. The court explained that the record did not indicate whether the resident had a guardian or the state was the resident’s guardian, and if the resident was a ward of the state than OLRS could receive the records without the guardian’s consent. The court granted Buckeye Ranch’s Motion to Dismiss the PAIMI Act regarding the restraint and seclusion logs. The court explained that while OLRS determines probable cause for PAIMI Act records access, the P&A never established probable cause for receiving these records. However, the court granted OLRS’s Motion for Summary Judgement to receive both the individual records and the restraint and seclusion logs under Ohio state law on April 12, 2005. In May 2005, the case settled before supplemental briefings were filed on the PAIMI Act individual records dispute. The case remains closed as of May 10, 2005.
Summary Authors
NDRN (3/19/2023)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/11992642/parties/ohio-legal-rights-service-v-the-buckeye-ranch-incorporated/
Graham, James L. (Ohio)
Harrison, John Richard (Ohio)
Kirkman, Michael (Ohio)
Smith, Ronald Lee (Ohio)
Rogers, Douglas Langston (Ohio)
See docket on RECAP: https://www.courtlistener.com/docket/11992642/ohio-legal-rights-service-v-the-buckeye-ranch-incorporated/
Last updated Aug. 5, 2025, 7:13 a.m.
State / Territory: Ohio
Case Type(s):
Key Dates
Filing Date: May 14, 2004
Closing Date: May 10, 2005
Case Ongoing: No
Plaintiffs
Plaintiff Description:
protection and advocacy system
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
Buckeye Ranch, Non-profit or advocacy
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: