Disability Rights California v. County of Alameda

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),…