Justia Juvenile Law Opinion SummariesArticles Posted in Class Action
Elisa W. v. City of New York
Plaintiffs-appellants, nineteen children in New York City’s foster care system, filed suit alleging “systemic deficiencies” in the administration of the City’s foster care system in violation of federal and state law. The named Plaintiffs moved to represent a class of all children who are now or will be in the foster care custody of the Commissioner of New York City’s Administration for Children’s Services and two subclasses. As remedies, they sought injunctive and declaratory relief to redress alleged class-wide injuries caused by deficiencies in the City’s administration—and the New York State Office of Children and Family Services’ oversight—of foster care. The district court denied Plaintiffs’ motion for class certification. Plaintiffs appealed, arguing that the district court erred in its analysis of the commonality and typicality requirements under Federal Rule of Civil Procedure 23(a). The Second Circuit vacated the district court’s order denying class certification and remanded. The court held that the district court erred in its analysis of commonality and typicality under Rule 23. The court explained that the district court did not determine whether commonality and typicality exist with respect to each of Plaintiffs’ claims. Instead, it concluded that commonality was lacking as to all alleged harms because “Plaintiffs’ allegations do not flow from unitary, non-discretionary policies.” The court held that this approach was legal error requiring remand. Further, the court wrote that here, the district court largely relied upon its commonality analysis to support its finding that typicality was not satisfied. Thus, the deficiencies identified in its commonality inquiry can also be found in its handling of typicality. View "Elisa W. v. City of New York" on Justia Law
Carolina Youth Action Project v. Alan Wilson
South Carolina law makes it a crime for elementary and secondary school students to act “disorderly” or in a “boisterous manner,”; use “obscene or profane language”; or “interfere with,” “loiter about,” or “act in an obnoxious manner” in (or sometimes near) a school. Four students who had been referred or charged under the disorderly conduct or disturbing schools laws, and a nonprofit organization that advocates for at-risk youth filed a putative class action challenging both laws as unconstitutionally vague. After denying a motion to dismiss, the district court certified one main class and two subclasses under the Federal Rule of Civil Procedure 23(b)(2). The court held that both laws were unconstitutionally vague as applied to elementary and secondary school students, and it permanently enjoined future enforcement of the disorderly conduct law against those students. South Carolina’s Attorney General—appealed, lodging multiple challenges to the district court’s rulings. The Fourth Circuit affirmed. The court reasoned that the district court committed no abuse of discretion here—not just because the challenged laws are facially invalid as applied to elementary and secondary school students but also because the subclasses demonstrated ongoing injury by the retention of existing records. A delinquency adjudication under South Carolina law may impair a minor’s future practice of law, application for military service, use of a driver’s license, and educational opportunities. Having concluded the laws may not be constitutionally enforced against South Carolina’s elementary and secondary students, the court saw no reason for allowing such continuing injuries to stand. View "Carolina Youth Action Project v. Alan Wilson" on Justia Law
Doe v. Shenandoah Valley Juvenile Center Commission
A facility caring for an unaccompanied child fails to provide a constitutionally adequate level of mental health care if it substantially departs from accepted professional standards. Appellants, a class of unaccompanied immigrant children detained at Shenandoah Valley Juvenile Center (SVJC), filed a class action alleging that the Commission fails to provide a constitutionally adequate level of mental health care due to its punitive practices and failure to implement trauma-informed care. The district court found that the Commission provides adequate care by offering access to counseling and medication.The Fourth Circuit held that neither the Flores Settlement nor SVJC's cooperative agreement prevent appellants from addressing their alleged injuries through the relief they seek from SVJC. On the merits, the court applied the Youngberg standard for professional judgment and reversed the district court's grant of summary judgment in favor of the Commission. The court explained that the district court incorrectly applied a standard of deliberate indifference when it should have determined whether the Commission substantially departed from accepted standards of professional judgment. Therefore, in light of the Youngberg standard, the district court must consider evidence relevant to the professional standards of care necessary to treat appellants' serious mental health needs. The court left it to the district court to determine in the first instance to what extent, if any, the trauma-informed approach should be incorporated into the professional judgment standard in this particular case. Accordingly, the court remanded for further proceedings. View "Doe v. Shenandoah Valley Juvenile Center Commission" on Justia Law
M.D., et al. v. Rick Perry, et al.
Plaintiffs, nine children in the custody of PMC, filed suit under 42 U.S.C. 1983 against three Texas officials, in their official capacities, seeking to represent a class of all children who were now, and all those who will be, in the State's long-term foster care. The gravaman of plaintiffs' complaint is that various system-wide problems in Texas's administration of its PMC subjected all of the children in PMC to a variety of harms. Applying the standards announced in the Supreme Court's recent opinion, Wal-mart Stores, Inc. v. Dukes, the court held that the district court failed to conduct the "rigorous" analysis required by Rule 23 in deciding to certify the proposed class. The court also held that the district court abused its discretion by certifying a class that lacked cohesiveness under Rule 23(b)(2). Accordingly, the court vacated the district court's class certification order and remanded for further proceedings. View "M.D., et al. v. Rick Perry, et al." on Justia Law
K.R. v. Commonwealth
Appellant was charged with complicity to commit assault in the first degree, attempted burglary in the first degree, and tampering with physical evidence in a juvenile proceeding. Appellant was sixteen years old at the time. The district court found there was no probable cause to believe Appellant had used a firearm in the commission of the offenses under Ky. Rev. Stat. 635.020(4) and therefore declined to order transfer of Appellant to circuit court as a youthful offender. The Commonwealth filed a petition for a writ of mandamus, asking the circuit court to order the district court to transfer Appellant as a youth offender. The circuit court granted the writ, and the court of appeals affirmed. The Supreme Court affirmed, holding that the writ of mandamus issued by the circuit court was not an abuse of discretion where (1) a crime committed by complicity can fall under the mandatory transfer provision of section 635.020(4), and complicity to commit an offense involving use of a firearm requires transfer when an offense involving direct use of a firearm would; and (2) the district court erred in finding that a firearm was not used in Appellant's offense. View "K.R. v. Commonwealth" on Justia Law
Jeff D., et al v. Otter, et al
Plaintiffs, a class of indigent children who suffered from severe emotional and mental disabilities, sued Idaho state officials more than three decades ago, alleging that the officials were providing them with inadequate care in violation of their constitutional and statutory rights. The parties reached agreements intended to remedy deficiencies in care and those agreements were embodied in three consent decrees entered and monitored by the district court. Plaintiffs appealed the 2007 order of the district court finding that defendants had substantially complied with the remaining Action Items, which were specified in an Implementation Plan that resulted from the third consent decree, asserting that it was error for the district court to apply the standard for civil contempt in determining whether to vacate the decrees. Plaintiffs further contended that the district court committed errors in fact and law in issuing protective orders barring them from taking supplemental depositions of appellee and two non-parties. The court held that the district court's application of the contempt standard with the imposition of the burden of proof on plaintiffs was error where the district court accepted the Action Items as the entire measure of compliance with the consent decree. Accordingly, the court reversed the order of the district court. The court also held that the district court committed no errors in upholding the assertion of the deliberative process privilege to one non-party and appellee, as well as the legislative privilege to the second non-party. Accordingly, the court did not abuse its discretion in issuing the protective orders.