Juvenile Migrant Detention Center Abuse Class Action Lawsuit Overview:
- Why: A US Supreme Court decision upheld a Fourth Circuit ruling, sending the case back to Virginia federal court under new terms.
- Who: A class action lawsuit alleges a juvenile detention center mistreated unaccompanied minors, but the center claims the complaint has no legal basis for the complaint.
- Where: The class action lawsuit was filed in Virginia federal court.
The U.S. Supreme Court declined to review a Fourth Circuit ruling that determined the threshold by which mental health care should be judged in a class action lawsuit alleging the mistreatment of unaccompanied migrant children by the Shenandoah Valley Juvenile Center (SVJC) in Virginia.
The high court’s decision, which came without explanation, sends the case back to Virginia federal court, which must now operate under the revised standard set by the Fourth Circuit. The circuit panel majority ruled that the adequacy of SVJC’s mental health care for detained minors should be based on the standard of professional judgment, which requires proof that the provided care deviates substantially from accepted professional practice.
The previous standard required proof that an official knew about and disregarded harm to the detainee.
The class action lawsuit made its way to the Supreme Court when the SVJC Commission petitioned the court to clarify which health care standard should be used in the case. The commission argued that a previous Third Circuit ruling set precedent for the “disregarded harm” standard.
The three-judge circuit panel majority, composed of US Circuit Judges Roger L. Gregory and Barbara Milano Keenan, determined that SVJC’s duty is to provide care for children’s physical and mental well-being, pointing to precedent set by the Supreme Court’s 1982 decision in Youngberg v. Romeo. Further, the majority noted that SVJC already considers the mental health needs of the children it accepts, confirming its intent to treat their needs.
Circuit Judge J. Harvie Wilkinson III dissented, calling the court “utterly unqualified” to determine what acceptable mental health care is.
Migrant Minors Allegedly Faced ‘Inhumane Conditions’ at Virginia Facility
The class action lawsuit against SVJC was first filed in 2017 by an unaccompanied minor, John Doe 4, who was detained at the center. Doe 4 had fled Honduras after he had been “hacked with a machete,” according to court documents.
The facility then allegedly exposed children in its care to further “brutal, inhumane conditions.”
When Doe 4 arrived at SVJC, staff diagnosed him with attention deficit hyperactivity disorder and post-traumatic stress disorder, according to the complaint. As punishment for self-harming, staff members allegedly pinned Doe 4 against the wall while another employee punched him in the ribcage.
In 2018, US District Judge Elizabeth Kay Dillon certified a class of unaccompanied, noncitizen children from Mexico and Central America detained at SVJC. However, Judge Dillon ruled that the class action lawsuit hadn’t provided evidence of inadequate mental health care, pointing to Doe 4’s psychological evaluation, medication, and counseling.
Do you think the judge should have allowed the juvenile migrant detention center abuse class action lawsuit to continue? Let us know in the comments below!
The proposed class of children is represented by Kelsi Brown Corkran of the Institute for Constitutional Advocacy and Protection, Georgetown University Law Center; Theodore A. Howard and Lukman Azeez of Wiley Rein LLP; and Mirela Missova of the Washington Lawyers’ Committee for Civil Rights and Urban Affairs.
SVJC is represented by Jason A. Botkins and Joshua S. Everard of Litten & Sipe LLP and Harold E. Johnson and Meredith M. Haynes of Williams Mullen.
The Juvenile Migrant Detention Center Abuse Class Action Lawsuit is Shenandoah Valley Juvenile Center Commission v. John Doe 4, et al., Case No. 21-48, in the Supreme Court of the United States.
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