Published January, 2004
A.M. v. Luzerne County Juvenile Detention Center, 372 F.3d 572 (3d Cir. 2004)
In this case, the U.S. Court of Appeals for the 3rd Circuit held that there was enough evidence to proceed to trial against a juvenile detention center for not protecting a minor under its care from abuse and not providing him with the psychological healthcare he required. This case highlights some of the constitutional protections for juveniles in state custody.
A.M., then 13-years-old, was arrested in July 1999 and taken to the Luzerne County Juvenile Detention Center ("the Center"); he remained there for a little over a month. During this period, A.M. suffered extensive abuse and physical violence from other residents. A.M. reported that the Center was aware of these assaults but did nothing to stop it. A.M. also suffers from Attention Deficit Hyperactivity Disorder ("ADHD"). During his stay at the Center, A.M. was given a psychiatric evaluation, which reported that he required a strictly planned day as well as medication on a continual basis in order to mitigate the impulsiveness and restlessness that caused him to act out. After this evaluation, Center officials did not call in a mental health professional to consult with staff on how to handle A.M.'s condition. In July 2001, A.M. brought suit against the Center's officials, child-care workers and medical staff (i.e. doctors and nurses) for violating his substantive due process rights guaranteed under the 14th Amendment to be free from harm and to receive appropriate medical treatment while in custody. The district court granted summary judgment for all defendants.
In this opinion, the court of appeals reversed and remanded the trial court's decision with respect to all parties except for the Center's medical staff. The court first noted that A.M. had a liberty interest in his personal security and wellbeing under the 14th Amendment. The court then noted that to determine whether A.M.'s Constitutional interest had been violated, the court must find "deliberate indifference" on the part of Center personnel. The court analyzed the evidence of "deliberate indifference" against Center officials, child-care workers and medical staff separately. The court found A.M. presented enough evidence showing that the Center had policies that were "deliberately indifferent" to A.M.'s safety and thus Center officials were liable as its official representatives. This included evidence of: 1) deficient hiring and staffing policies, 2) inadequate training of staff 3) lack of policies to ensure youth safety and 4) lack of policies regarding residents' physical and mental health needs. The court also found that Center officials were individually liable for failing to develop adequate policies and supervise their subordinates. Center child-care workers were found potentially liable as individuals because they witnessed repeated beatings of A.M. by other Center residents but did nothing to intervene. However, the court did not find Center medical staff liable because A.M. did not provide evidence supporting the allegation that medical staff did not disseminate information about A.M.'s mental health history or take other steps in response to A.M.'s medical condition.
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