Sonnenberg v. Disability Rights Idaho, Inc.

On March 7, 2016, the United States District Court for the District of Idaho issued a declaratory judgment in Sonnenberg v. Disability Rights Idaho, Inc, granting to a protection and advocacy organization (“P&A”) access to a coroner’s records under the Protection and Advocacy for Individuals with Mental Illness Act of 1986, 42 U.S.C. § 10801 et seq. (“PAIMI”). The dispute arose when a county coroner refused to provide its investigatory records to the P&A, arguing that a P&A’s right of access to records under PAIMI does not extend to a coroner’s records of its death investigation. The coroner had also cited privacy concerns and questioned the P&A’s probable cause to investigate the death. The court held that the coroner was an “agency charged with investigating” reports of incidents of abuse, neglect, and injury under PAIMI. The court granted summary judgment in favor of the P&A, held that the coroner had violate PAIMI by withholding its investigatory records, and permanently enjoined the coroner from withholding the records from the P&A.