Case: Keith G. v. Bilbray

90-626554 | California state trial court

Filed Date: July 20, 1990

Closed Date: 1995

Clearinghouse coding complete

Case Summary

On July 20, 1990, a class action lawsuit was filed under 42 U.S.C. § 1983 in the Superior Court of the State of California in and for the County of San Diego on behalf of all juveniles currently detained at the San Diego Juvenile Hall, against San Diego County, California, and county corrections personnel. The plaintiffs, represented by the A.C.L.U. Foundation of San Diego and Imperial Counties and the San Diego Volunteer Lawyer Program, alleged that overcrowding at Juvenile Hall deprived deta…

On July 20, 1990, a class action lawsuit was filed under 42 U.S.C. § 1983 in the Superior Court of the State of California in and for the County of San Diego on behalf of all juveniles currently detained at the San Diego Juvenile Hall, against San Diego County, California, and county corrections personnel. The plaintiffs, represented by the A.C.L.U. Foundation of San Diego and Imperial Counties and the San Diego Volunteer Lawyer Program, alleged that overcrowding at Juvenile Hall deprived detainees of their constitutional rights and violated state law. Plaintiffs sought declaratory and injunctive relief.

Because of overcrowding at Juvenile Hall, detainees were subject to long periods of lock-down. During lock-down, detainees did not have access to toilets, clean clothing, and adequate quantities of food. In addition, overcrowding exacerbated the inadequacy of medical treatment, mental health care, suicide prevention, educational opportunities, rehabilitative programming, and staff monitoring. As the result of space shortages, juveniles awaiting trial were confined with convicted juveniles in rooms housing more detainees then their capacity and convicted female juveniles were transferred daily from Juvenile Hall, where they slept, to day programs in a girls' facility.

On Oct. 12, 1992, the Superior Court of the State of California in and for San Diego County (Judge Robert J. O'Neill) held that the conditions at Juvenile Hall violated detainees' Eighth and Fourteenth Amendment rights. The court ordered the County (1) to abide by population caps and house no more than two juveniles in a single-occupancy room, (2) to ensure staff-to-minor ratios of 1:10 during waking hours and 1:30 at night, (3) to screen all juveniles for mental illnesses and offer responsive mental health treatment, (4) to educate and rehabilitate youths still detained at Juvenile Hall fifteen days or more after conviction and (5) to submit a long-term plan for increasing capacity to the court within forty-five days.

The First Division of the Fourth District of the California Court of Appeal (Judge Patricia D. Benke) reversed, remanded, and ordered judgment entered for the County. Keith G. v. Bilbray, 43 Cal. Rptr. 2d 277 (Cal. Ct. App. 1995) (depublished). The Court of Appeal held that a court could only find that juvenile detainees' rights were violated if there was substantial evidence of discrete deprivations. The Court of Appeal dismissed the trial court's eighty-nine pages of findings as speculative and not directly connected to constitutional violations.

The California Supreme Court granted the plaintiffs' petition for review. Keith G. v. Bilbray, 904 P.2d 372 (Cal. 1995). The Youth Law Center filed an amicus curiae brief on behalf of the plaintiffs, supporting the trial court's decision with precedent from other states. The California Supreme Court dismissed and remanded. Keith G. v. Bilbray, 912 P.2d 1147 (Cal. 1996). We have no record of further proceedings in this case.

Summary Authors

Elizabeth Chilcoat (5/22/2006)

People


Judge(s)

Benke, Patricia D. (California)

Lucas, Malcolm Millar (California)

O'Neill, Robert J. (California)

Attorneys(s) for Plaintiff

Budd, Jordan C. (California)

Dougan, Karin A. (California)

Landon, Alexander L. (California)

Missakian, Elizabth (California)

Mittermiller, James J. (California)

Wheeler, Betty (California)

Attorneys(s) for Defendant

Bardsley, Diane (California)

Judge(s)

Benke, Patricia D. (California)

Lucas, Malcolm Millar (California)

O'Neill, Robert J. (California)

Attorneys(s) for Plaintiff

Budd, Jordan C. (California)

Dougan, Karin A. (California)

Landon, Alexander L. (California)

Missakian, Elizabth (California)

Mittermiller, James J. (California)

Wheeler, Betty (California)

Attorneys(s) for Defendant

Bardsley, Diane (California)

Hagar, John H. Jr. (California)

Harmon, Lloyd (California)

Northrup, Nathan (California)

Taylor, Timothy B. (California)

Other Attorney(s)

Bell, James Raymond (California)

Burrell, Susan L. (California)

Meieran, Sharon (California)

Peters, Clark M. (Ohio)

Udell, Lei K. (California)

Warboys, Loren M. (California)

Wilber, Shannan l. (California)

Documents in the Clearinghouse

Document

90-626554

Docket

July 20, 1990

July 20, 1990

Docket

90-626554

Class Action Civil Rights Claim for Declaratory and Injunctive Relief and Writ of Mandate General Civil

July 20, 1990

July 20, 1990

Complaint

D018045

Opinion

California state appellate court

43 Cal.Rptr. 277

Aug. 21, 1995

Aug. 21, 1995

Order/Opinion

S048615

Ruling on Petition for Review

California state supreme court

904 P.2d 372

Oct. 27, 1995

Oct. 27, 1995

Order/Opinion

S048615

Application for Leave to File Amicus Curiae Brief of Youth Law Center on Behalf of Plaintiffs and Respondents and Amicus Curiae Brief of YLC on Behalf of Plaintiffs and Respondents

Feb. 16, 1996

Feb. 16, 1996

Pleading / Motion / Brief

S048615

Opinion Review Dismissal

California state supreme court

912 P.2d 1147

March 28, 1996

March 28, 1996

Order/Opinion

Resources

Docket

Last updated May 12, 2022, 8 p.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: California

Case Type(s):

Juvenile Institution

Key Dates

Filing Date: July 20, 1990

Closing Date: 1995

Case Ongoing: No

Plaintiffs

Plaintiff Description:

all juveniles currently detained at the San Diego Juvenile Hall

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Youth Law Center

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

San Diego County, County

San Diego County Juvenile Hal (San Diego), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Freedom of speech/association

Availably Documents:

Complaint (any)

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

Litigation

Order Duration: 1992 - 1995

Issues

General:

Education

Food service / nutrition / hydration

Sanitation / living conditions

Suicide prevention

Totality of conditions

Crowding:

Crowding / caseload

Affected Gender:

Male

Medical/Mental Health:

Medical care, general

Mental health care, general

Suicide prevention

Type of Facility:

Government-run