This case was brought by Disability Rights California (“DRC”), a nonprofit corporation, to challenge the systemic institutionalization and segregation of Alameda County residents with serious mental health disabilities. On July 30, 2020, DRC filed this lawsuit in the U.S. District Court for the Northern District of California and named the County of Alameda (“the County”), Alameda Health System, and Alameda County Behavioral Health Care Services (“County Behavioral Health”) as defendants. DRC brought the suit under the Americans with Disabilities Act of 1990, or 42 U.S.C. §§ 12111 et seq. DRC sought declaratory and injunctive relief, as well as attorney’s fees, alleging that the defendants had violated the ADA, as well as section 504 of the Rehabilitation Act of 1973 (28 U.S.C. § 794 et seq.) and sections 11135-11139 of the California Government Code, by detaining mentally disabled individuals for longer than needed and failing to provide them proper treatment and services.

On October 13, 2020, Alameda Health System filed a motion to dismiss and a motion to strike the complaint. It argued that DRC lacked standing because DRC’s complaint depended on the County creating community-based mental health services, a future event that may never occur. The County and County Behavioral Health filed similar motions shortly thereafter.

On January 21, 2021, Judge Charles R. Breyer issued an order granting the defendants’ motions to dismiss with leave to amend, finding that DRC had failed to plausibly allege disability discrimination under the relevant statutes. Specifically, Judge Breyer found that the claims against the Health System failed because they centered on the failure to provide services rather than the setting. And Judge Breyer found that the claims against the County failed because the plaintiffs had not identified specific programs being provided in institutionalized settings that could be provided elsewhere. 2021 WL 212900. Judge Breyer also found that DRC had standing with respect to all defendants because DRC adequately pleaded an injury suffered by its constituents that could be traced to the defendants’ conduct. DRC has alleged that its Constituents have been unnecessarily institutionalized and continue to face a risk of unnecessary institutionalization as a result of Defendants’ practices and lack of services; and, DRC showed that this injury could be redressed by a favorable decision. Id.

DRC submitted an amended complaint on February 23, 2021.

Anjali Baliga - 03/04/2021


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