Arnold v. Sarn: A Landmark Case for Supportive Housing and Mental Health
If you work in housing or behavioral health in Arizona, you may have heard the name Arnold v. Sarn. The case dates back more than 40 years, but its impact can still be seen in Arizona’s behavioral health and supportive housing systems today.
The class action lawsuit was filed in 1981 after concerns that Arizona and Maricopa County were not providing the community mental health services required under state law. Courts ultimately agreed, leading to decades of work to strengthen community based services for people with serious mental illness.
That work eventually included expanded access to Permanent Supportive Housing, supported employment, Assertive Community Treatment, and peer and family support services.
So why does a court case from 1981 still matter today? Its history helps explain how many of the housing and behavioral health services we know today came to be, including services that remain central to HOM’s work.
Key Takeaways
- Arnold v. Sarn began in Arizona in 1981.
- The case focused on access to community mental health services.
- Arizona courts found that required services were not being adequately provided.
- A 2014 agreement expanded several community-based services.
- Permanent supportive housing was a major part of those efforts.
Arnold v. Sarn helped shape the community based behavioral and supportive housing systems Arizona has today.
The Background of Arnold v. Sarn
The lawsuit began at a time when many people with serious mental illness lacked access to coordinated services in the community. The plaintiffs argued that Arizona had not created the comprehensive community mental health system required by state law and had not met their responsibilities to people with serious mental illness.
Who Were Arnold and Sarn?
Charles “Chick” Arnold was an attorney who specialized in areas including mental health law. He served as guardian for the plaintiffs when the lawsuit began in 1981.
James E. Sarn served as director of the Arizona Department of Health Services from 1980 to 1983.
Why Was the Lawsuit Filed?
Rather than focusing on one specific program, Arnold v. Sarn addressed a larger question: Was Arizona meeting its responsibility under state law to provide a coordinated system of community mental health care for people with serious mental illness?
The courts ultimately determined that the state and Maricopa County had not fully met those obligations.
The case focused on Arizona’s responsibility to provide a coordinated system of community mental health services.
What Did the Courts Decide?
The trial court ruled in 1986 that Arizona and Maricopa County had violated their statutory duties. The Arizona Supreme Court affirmed that ruling in 1989.
The decision reinforced the state’s responsibility to provide community mental health services required under Arizona law.
Unlike some later disability rights cases, Arnold v. Sarn was rooted in Arizona law. The case began before the Americans with Disabilities Act and the later U.S. Supreme Court decision in Olmstead v. L.C.
Decades of Reform Following Arnold v. Sarn
The 1989 court decision was far from the end of Arnold v. Sarn. The case remained active for many years as Arizona worked to improve its behavioral health system. The parties addressed funding, service capacity, quality standards, monitoring, and other issues over time.
In January 2014, the parties reached a final agreement known as the Stipulation for Providing Community Services and Terminating Litigation.
The agreement established specific commitments for expanding community-based services in Maricopa County. It also created methods for evaluating the quality and availability of those services.
The case led to decades of changes in Arizona’s community based behavioral health system.
The 2014 Arnold v. Sarn Agreement
The 2014 agreement focused on four major service areas:
Assertive Community Treatment
Assertive Community Treatment, often called ACT, uses multidisciplinary teams to provide intensive community-based services.
ACT teams help eligible individuals manage behavioral health needs while living in the community. The 2014 agreement called for Arizona to expand the number of ACT teams serving Maricopa County.
Supported Employment
Supported Employment services help people with serious mental illness prepare for, find, and maintain competitive employment.
The agreement required Arizona to expand Supported Employment capacity so more individuals could receive these services.
Permanent Supportive Housing
Permanent Supportive Housing combines affordable housing with supportive services that help participants maintain housing and stability.
The 2014 agreement called for 1,200 additional supportive housing opportunities in Maricopa County by the end of fiscal year 2016.
Supportive housing resources can include rental subsidies, housing vouchers, bridge funding, and related housing services.
Peer and Family Support Services
Peer support services involve people who use their own lived experience to support others in recovery.
Family support services help family members better understand behavioral health needs and provide effective support to loved ones.
The 2014 agreement also expanded access to these services throughout Maricopa County.
The reforms helped expand opportunities for people with serious mental illness to receive services while living in their communities.
Why Permanent Supportive Housing Matters
Permanent Supportive Housing became an important part of the reforms connected to Arnold v. Sarn. The model combines stable housing with services that help people remain successfully housed while receiving support in their community.
Permanent Supportive Housing can also provide participants with tenancy rights, housing choice, and opportunities to live in integrated communities.
For program participants, stable housing can provide a foundation for recovery and greater independence. For service providers, housing gives them a stable setting from which they can help participants work toward other goals.
Landlords also play an important role by providing rental housing within the community. Their participation helps supportive housing programs offer participants a broader range of housing options.
Community-Based Services and Housing Choice
One of the broader themes connected to Arnold v. Sarn is the shift toward providing behavioral health services within the community. Housing can be part of a larger network of behavioral health care, employment assistance, peer support, and other services.
Housing choice matters too. Supportive housing should provide meaningful opportunities for participants to live throughout the community. When housing opportunities become concentrated in only a small number of properties or neighborhoods, those choices can become limited.
Who Does Arnold v. Sarn Apply To?
The Arnold v. Sarn agreement has a specific population and geographic focus.
AHCCCS identifies Arnold v. Sarn class members as adults with a Serious Mental Illness designation who live in Maricopa County. The 2014 agreement applies specifically to eligible members in Maricopa County.
The 2014 agreement did not create identical requirements for every behavioral health or supportive housing program throughout Arizona.
However, AHCCCS notes that the principles incorporated into Maricopa County’s behavioral health system are encouraged statewide.
Arnold v. Sarn was rooted in Arizona law and the state’s responsibility to provide community mental health services.
What Arnold v. Sarn Means Today
Arnold v. Sarn remains relevant because the services expanded through the case continue to play an important role in Arizona’s behavioral health system.
Since 2016, AHCCCS has continued supporting implementation of the four major service areas in Maricopa County. Current monitoring and reporting continue to evaluate these services.
More than four decades after the case began, that connection between housing and community-based support remains central to the work happening across Arizona today.
- Program participants gained greater access to community-based services, supportive housing, employment services, and peer support.
- Service providers became part of a more connected system that brings behavioral health services, housing, and other community supports together.
- Landlords and property owners play an important role by providing rental housing that expands community-based options for program participants.
- Community stakeholders can see how housing, behavioral health services, employment, and peer support work together as part of a broader support system.
Frequently Asked Questions
What is Arnold v. Sarn?
Arnold v. Sarn was a class-action lawsuit filed in 1981. It challenged Arizona’s failure to provide the comprehensive community mental health services required under state law.
When was Arnold v. Sarn filed?
The lawsuit was filed in 1981. The trial court ruled in favor of the plaintiffs in 1986, and the Arizona Supreme Court affirmed that decision in 1989.
Who were Arnold and Sarn?
Charles “Chick” Arnold was an attorney and guardian for the plaintiffs when the lawsuit began. James E. Sarn served as director of the Arizona Department of Health Services from 1980 to 1983.
What did the court decide?
The courts found that Arizona and Maricopa County had statutory responsibilities to provide community mental health services and had not fully met those responsibilities.
When was Arnold v. Sarn settled?
The parties reached a final agreement in January 2014. The agreement established commitments for expanded community services and provided a path toward ending the litigation.
What services were expanded under the 2014 agreement?
The agreement focused on Assertive Community Treatment, Supported Employment, Permanent Supportive Housing, and peer and family support services.
How did Arnold v. Sarn affect supportive housing?
The 2014 agreement required Arizona to expand supportive housing capacity in Maricopa County. It called for 1,200 additional supportive housing opportunities by the end of fiscal year 2016.
Who is an Arnold v. Sarn class member?
AHCCCS identifies class members as adults with a Serious Mental Illness designation who live in Maricopa County.
Does Arnold v. Sarn apply throughout Arizona?
The 2014 agreement applies specifically to eligible members in Maricopa County. However, AHCCCS encourages the principles incorporated into that system throughout Arizona.
Is Arnold v. Sarn still relevant today?
Yes. AHCCCS continues to support and monitor the community-based services established through the agreement. The case also remains an important part of the history of supportive housing and behavioral health services in Arizona.
