Case: Disability Rights Ohio v. Buckeye Ranch
2:18-cv-00906 | U.S. District Court for the Southern District of Ohio
Filed Date: Aug. 17, 2018
Closed Date: Aug. 5, 2019
Clearinghouse coding complete
Case Summary
This is a case about a protection and advocacy agency's (P&A) records and residents access authority for minors where parents or guardians do not consent to the P&A requesting records or interviewing residents. On August 17, 2018, Buckeye Ranch, a youth residential mental health facility, filed this lawsuit in the U.S. District Court for the Southern District of Ohio against Disability Rights Ohio, Ohio’s Protection and Advocacy (P&A) agency. Buckeye Ranch alleged that Disability Rights Ohio exceeded its authority under the Protection and Advocacy for Individuals With Mental Illness (PAIMI) Act when they sought records and interviews with residents without obtaining consent from their parents or guardians. Buckeye Ranch also alleged that the PAIMI Act violated the Fourth Amendment of the U.S. Constitution. Judge Edmund A. Sargus, Jr. presided over this matter.
This lawsuit began when Disability Rights Ohio opened an investigation into Buckeye Ranch concerning five incidents involving four children that Buckeye Ranch self-reported to Ohio state authorities. During the investigation, Disability Rights Ohio asserted that they could speak with facility residents without the consent of their parents or guardians. Buckeye Ranch sought a Temporary Restraining Order that barred Disability Rights Ohio from speaking with residents or accessing their records without consent from their parents or guardians. Moreover, Buckeye Ranch asserted that the P&A lacked probable cause for this investigation. Disability Rights Ohio filed a counterclaim, alleging that Buckeye Ranch’s denial violated their PAIMI Act authority (the counterclaim by Disability Rights Ohio’s docket number is 2:18-cv-00894).
On March 26, 2019, the court decided both cases. Here, the court denied Buckeye Ranch’s motion and granted Disability Rights Ohio’s Motion for Preliminary Injunction. The court explained that the children in question were wards of the state, and the PAIMI Act permitted records access without consent in such circumstances. Moreover, the court noted that even if children had parents or guardians, the PAIMI Act only required that the P&A notify the parent or guardian of the records request. The court rejected Buckeye Ranch’s claim that Disability Rights Ohio lacked probable cause because the P&A determines probable cause, not outside parties. Consequentially, the court then determined that Disability Rights Ohio did not need the consent of parents or guardians to interview residents upon establishing probable cause for an investigation. The court also rejected the claim that the PAIMI Act violated the Fourth Amendment because the established definition for PAIMI Act probable cause differed from the Fourth Amendment. The case closed on August 5, 2019.
Summary Authors
NDRN (3/19/2023)
People
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/7686769/parties/the-buckeye-ranch-inc-v-disability-rights-ohio/
Sargus, Edmund A. (Ohio)
Meluch, Maribeth (Ohio)
Jendretzky, Michel Marie (Ohio)
Newhouse, D Wesley (Ohio)
Shouvlin, David P (Ohio)
Documents in the Clearinghouse
Docket
See docket on RECAP: https://www.courtlistener.com/docket/7686769/the-buckeye-ranch-inc-v-disability-rights-ohio/
Last updated April 9, 2026, 5:11 a.m.
Case Details
State / Territory:
Case Type(s):
Key Dates
Filing Date: Aug. 17, 2018
Closing Date: Aug. 5, 2019
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Youth residential mental health facility
Attorney Organizations:
NDRN/Protection & Advocacy Organizations
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
Non-profit or advocacy
Buckeye Ranch
Case Details
Causes of Action:
Protection and Advocacy for Individuals with Mental Illness (PAIMI) Act, 42 U.S.C. § 10801
Other Dockets:
Southern District of Ohio 2:18-cv-00906
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Defendant
Relief Granted:
Source of Relief:
Issues
Disability and Disability Rights:
Case Summary of Disability Rights Ohio v. Buckeye Ranch, Civil Rights Litig. Clearinghouse, http://www.dev.clearinghouse.net/case/18495/ (last updated 3/19/2023).