Case: United States v. City of Meridian

DOJ Investigation; Lawsuit (2011–2012)

On December 1, 2011, the U.S. Department of Justice (DOJ) Civil Rights Division launched an investigation into the Meridian Police Department and the Lauderdale County Youth Court under 42 U.S.C. § 14141 and 42 U.S.C. § 2000d. The DOJ later expanded its investigation to include the Mississippi Division of Youth Services. On August 10, 2012, the DOJ published findings that these agencies had a pattern or pattern or practice of arresting public school students without probable cause to believe that an illegal offense had been committed, thereby violating the children’s constitutional rights under the Fourth, Fifth, and Fourteenth Amendments by. In response, the City of Meridian revised its policies and limited the circumstances under which police officers could arrest youths on school grounds.

Determining that the policy revision did not adequately resolve the constitutional violations, on October 24, 2012, the United States filed suit against the City of Meridian, Lauderdale County, two Lauderdale County Youth Court judges, the State of Mississippi, the Mississippi Department of Human Services, and the Mississippi Division of Youth Services (DYS) in the U.S. District Court for the Southern District of Mississippi. The DOJ alleged that the defendants operated a "school-to-prison pipeline" and sought declaratory relief, a permanent injunction against the unlawful practices, policy reforms, and other equitable relief. The case was assigned to District Judge Henry T. Wingate.

This case marked the first lawsuit based on a "school-to-prison pipeline" legal theory. In the four-count complaint, DOJ explained the parties alleged involvement in this pipeline, and their corresponding constitutional violations. First, the complaint alleged that the City of Meridian, through the Meridian Police Department (MPD), violated the Fourth Amendment and § 14141 by arresting students in the Meridian Public School District without probable cause and by failing to require or to make individualized assessments of probable cause. Second, that Lauderdale County and the two named county judges violated due process rights of children subject to the jurisdiction of the county’s youth court by denying them access to meaningful procedural protections. Third, that Lauderdale County and the Mississippi Division of Youth Services violated the due process rights of juveniles through their policies, procedures, and practices with respect to probation and probation revocation by failing to provide probable cause hearings, appropriate protection against self-incrimination, or any procedural safeguards to juveniles alleged to have violated probation. Lastly, that all the defendants, working in concert, violated the substantive due process rights of juveniles by incarcerating students for probation violations resulting from suspensions for alleged school disciplinary infractions rooted in a written probation contract used in Lauderdale County that the DOJ asserted was void for vagueness.

Motion to Dismiss and Transfer of Case (2012–2013)

On December 7, 2012, the defendants filed a motion to dismiss, citing the Younger abstention doctrine. On September 4, 2013, Judge Wingate denied the motion, noting that the government's interest in eliminating a pattern or practice of constitutional violations was not necessarily identical to the interests of individual children facing delinquency proceedings in state court. Moreover, the government's interest was not so "intertwined" with such individuals as to justify barring prospective relief to a person not a party to the challenged state actions.

On December 26, 2013, the case was transferred to the Northern Division and assigned a new case number.

Settlement Negotiations (2014–2015)

Between 2014 and early 2015, the parties engaged in discovery and settlement negotiations. On June 19, 2015, the DOJ announced it had reached settlement agreements with the State of Mississippi and with the City of Meridian. Lauderdale County and the defendant county youth court judges were not party to either settlement. See DOJ 15-768 (D.O.J.), 2015 WL 3809399.

On September 18, 2015, Judge Wingate issued orders approving the two settlement agreements.  

The settlement agreement with the City of Meridian focused on improving the conduct of MPD in Meridian's public schools. It limited MPD's authority to arrest juveniles at school, required additional documentation of school-based arrests, and instituted reforms related to MPD training, complaint procedures, data collection, and coordination with the Meridian Public School District Police Department. The parties agreed that a Police Independent Auditor would supervise compliance and that the agreement would terminate after the city was in “substantial compliance” with the settlement for 12 consecutive months. On March 18, 2016, the parties agreed on a Police Independent Auditor after a budget dispute, and Judge Wingate approved their choice on March 25, 2016.

The settlement agreement with the State of Mississippi focused on improving the conduct of the Mississippi Division of Youth Services, which managed probation for youths. It required the division to inform youths on probation of the probation process and their rights within it, limited the division’s ability to incarcerate youths for probation violations, increased procedural protections for youths on probation, and initiated training and community involvement programs. The parties agreed that a Probation Services Independent Auditor would supervise compliance and that the agreement would terminate after the division was in “substantial compliance” with the settlement for 12 consecutive months. On January 5, 2016, the parties notified the court that they had agreed on the Probation Services Independent Auditor.

Continued Litigation Against Lauderdale County and County Youth Court Judges (2014–2019)

While the DOJ successfully reached settlements with the City of Meridian and the State of Mississippi, there was no settlement with Lauderdale County or the county youth court judges.  The case against these defendants proceeded. On November 25, 2014, the defendant county judges filed a motion to dismiss, citing absolute judicial immunity and the Rooker-Feldman doctrine, which prevents parties that lost in state court from re-litigating their claims in federal court. Lauderdale County joined the motion to dismiss on November 28, 2014. 

Judge Wingate granted the motion to dismiss on September 30, 2017. While he found that the Rooker-Feldman doctrine did not apply, Judge Wingate granted the motion under the theory of absolute judicial immunity, which bars most claims against judges acting within their official capacities and jurisdiction, and declined the United States' invitation to apply 42 U.S.C. § 14141 to judges. Judge Wingate ruled the case against Lauderdale County be dismissed as well because it was "inextricably intertwined" with that against its judges. 2017 WL 6810621. On November 28, 2017, the United States appealed to the U.S. Court of Appeals for the Fifth Circuit, where the matter was assigned to a three-judge panel consisting of Circuit Judges Thomas M. Reavley, Jennifer Walker Elrod, and Stephen A. Higginson. The panel issued an opinion on February 1, 2019, affirming the district court’s ruling. 914 F.3d 960.

Compliance Monitoring and Status Updates (2016–2018)

Throughout 2016 and 2017, the independent auditors monitored compliance with the settlement agreements and submitted a number of status updates. On January 16, 2018, the Police Independent Auditor filed a report stating that the City of Meridian and MPD were in substantial compliance with all of the settlement's requirements. The parties agreed to transfer the responsibility for monitoring compliance from the independent monitor to the federal government, which submitted its first compliance report on September 12, 2018, finding that the City of Meridian and MPD remained in substantial compliance.

In contrast, the Probation Services Independent Auditor's Fifth Report, filed on April 2, 2018, identified several areas in which the State of Mississippi was not in substantial compliance with its settlement agreement. While recognizing that the state had made progress, the auditor found that the state had failed to fully meet its obligation to review its policies and procedures, draft new policies and procedures when necessary, and improve training as required by the agreement. The auditor also noted that their ability to gain a full picture of the Division of Youth Services’ interactions with judges, court personnel, youth, families and others was limited by the decision of the county and the defendant youth court judges to refuse the monitor access to youth court files.

Termination of City of Meridian’s Settlement Agreement (2019-2022)

On May 23, 2019, the DOJ and the City of Meridian filed a joint motion to terminate the settlement agreement governing the city, MPD, and Meridian public schools, citing the fact that the city had been in substantial compliance with the agreement for 12 consecutive months. Judge Wingate issued an order on February 23, 2022, granting the motion and terminating the agreement. In his order, Judge Wingate noted that he had waited to rule on the motion because he “wanted assurance that adherence to the Agreement was not a temporary notion, but a lasting and enduring effort to create viable ingrained policies, appropriate new procedures and automatic responses which would nullify any vestige or accusation that the City of Meridian manifested a ‘school-to-prison pipeline.’” 2022 WL 551261.

Ongoing Enforcement of State of Mississippi’s Settlement Agreement (2019 – Present)

On April 15, 2019, the State of Mississippi and the DOJ informed the court that the federal government would begin monitoring the state’s compliance with the settlement agreement. The first federal monitoring report, submitted to the court in July 2019, found the state to be in substantial compliance with all provisions of the settlement agreement other than certain provisions relating to the training the Division of Youth Services provides to youth court counselors involved in providing delinquency and probation services in youth court. The monitor directed the division to complete work on a desktop guide and orientation materials and to ensure that all staff have received training on dispositional planning, including effective use and development of case supervision plans. The second federal monitoring report, submitted in February 2020, found the state to be in substantial compliance with all provisions of the agreement.

On May 17, 2021, the federal monitors submitted their third and most recent monitoring report in which they noted that the state had sustained substantial compliance of all of the settlement agreement’s provisions for twelve consecutive months and that as such the agreement was “ripe for termination.”

As of January 2025, neither party has filed a motion for termination and the settlement agreement remains in effect.