Case: Morgan v. Sproat

3:75-cv-00021 | U.S. District Court for the Southern District of Mississippi

Filed Date: Feb. 4, 1975

Case Ongoing

Clearinghouse coding complete

Case Summary

On February 4, 1975, juveniles at the Oakley Training School (OTS), a Mississippi state institution for delinquent boys, filed a class action lawsuit against the Department of Youth Services in the United States District Court for the Southern District of Mississippi pursuant to 42 U.S.C. § 1983. The plaintiffs, represented by Community Legal Services, alleged that the institution did not fulfill its intended purpose to rehabilitate youth and that the conditions at the institution violated thei…

On February 4, 1975, juveniles at the Oakley Training School (OTS), a Mississippi state institution for delinquent boys, filed a class action lawsuit against the Department of Youth Services in the United States District Court for the Southern District of Mississippi pursuant to 42 U.S.C. § 1983. The plaintiffs, represented by Community Legal Services, alleged that the institution did not fulfill its intended purpose to rehabilitate youth and that the conditions at the institution violated their constitutional rights. The complaint alleged that the boys were punished by being placed in intensive treatment units where they were isolated for extended periods of time and that counseling programs, medical care, and legal services were all unconstitutionally deficient. They sought injunctive relief.

On April 3, 1975, Judge Walter Nixon certified the case as a class action of all present and future students confined at OTS, which at the time of filing consisted of 350 boys between the ages of 15 and 20. On October 8, 1975, the court appointed experts to the case, including two clinical psychologists.

On November 22, 1975, the court issued an order relating to disciplinary procedures. Under the order, defendants agreed to provide procedural safeguards, including prior notice and an impartial evidentiary hearing, to all OTS students accused of violating school rules and regulations. Defendants also promulgated a new code of rules, adopted by the court on November 26, 1976.

On April 18, 1977, Judge Nixon found that the policies in place at OTS violated plaintiffs' constitutional rights. Morgan v. Sproat, 432 F.Supp. 1130 (S.D. Miss. 1977). First, the court held the plaintiffs' due process rights were being violated, because the adjudication procedure used to commit juveniles to the state institution were developed with the intention that it be a therapeutic rather than punitive incarceration. As such, plaintiffs were being sent to a punitive state facility without due process for such punishment. Secondly, the court found that the conditions at the institution violated the Eighth Amendment's prohibition on cruel and unusual punishment. The court ordered that defendants were enjoined from placing juveniles in intensive treatment units except when they posed an immediate threat, and then for no more than twenty-four hours. The court further ordered that defendants develop educational, vocational, and recreational programming to meet the needs of the juveniles. The court enjoined defendants from isolating youth "whose psychological, emotional or intellectual status make isolation inappropriate." Defendants were also ordered to address overcrowding issues at the facility as well as increase access to dental and medical care. Finally, the court ordered that defendants forward requests by juveniles for legal representation to a legal services program. Attorney's fees were awarded.

The defendants continued to file reports of their progress and on July 3, 1981, Judge Nixon found that the no further reports were necessary as the defendants were found to be in compliance with the 1977 order.

On May 24, 2001, a new set of plaintiffs filed a motion to submit a supplemental complaint, but this motion was denied on April 1, 2004. In the meantime, however,the U.S. Department of Justice filed a report which revealed poor conditions at OTS. The report indicated that OTS had made little or no progress since 1977. After the DOJ released this report in 2003, the Southern Poverty Law Center joined the Mississippi Center for Justice to take over as class counsel in the litigation.

The DOJ filed its own lawsuit, U.S. v. Mississippi, 3:03-cv-01354-HTW-JCS, JI-MS-0004 in this Clearinghouse. Plaintiffs moved to consolidate the two cases; the U.S. did not oppose consolidation, but the Court refused to grant it. So this case continued on separately. No substantive activity appears in the docket after that, but new lawyers are added, and others withdrawn (as they changed jobs), and on June 26, 2015, the case was reassigned to Magistrate Judge Robert H. Walker. So it seems that the case is ongoing.

Summary Authors

Emilee Baker (5/16/2006)

Abigail DeHart (6/12/2017)

Elena Malik (2/1/2020)

Related Cases

U.S. v. Mississippi, Southern District of Mississippi (2003)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/16214583/parties/morgan-v-sproat/


Judge(s)

Nixon, Walter Louis Jr. (Mississippi)

Walker, Robert H. (Mississippi)

Attorneys(s) for Plaintiff

Atwood, Bear Hailey (Mississippi)

Bedi, Sheila A. (Mississippi)

Bergmark, Martha (Mississippi)

Brownstein, Rhonda C. (Alabama)

Carroll, Vanessa (Mississippi)

Cockrell, Corrie Wynette (Mississippi)

Graham, Grace Gabriel (Alabama)

Juneja, Poonam (California)

Judge(s)

Nixon, Walter Louis Jr. (Mississippi)

Walker, Robert H. (Mississippi)

Attorneys(s) for Plaintiff

Atwood, Bear Hailey (Mississippi)

Bedi, Sheila A. (Mississippi)

Bergmark, Martha (Mississippi)

Brownstein, Rhonda C. (Alabama)

Carroll, Vanessa (Mississippi)

Cockrell, Corrie Wynette (Mississippi)

Graham, Grace Gabriel (Alabama)

Juneja, Poonam (California)

Levins, Kristen M. (Mississippi)

Lipow, Danielle Jeannine (Alabama)

Miller, David B. (Mississippi)

Owens, Jody E. II (Mississippi)

Payne, Shirley (Mississippi)

Powell, Barry H. (Mississippi)

Ramberg, Charles H. (Mississippi)

Attorneys(s) for Defendant

Googe, P. Roger Jr. (Mississippi)

Documents in the Clearinghouse

Document
1

Docket [Paper]

Oct. 5, 2009 Docket

Docket [PACER]

Sept. 24, 2019 Docket

Memorandum Opinion

432 F.Supp. 1130

April 18, 1977 Order/Opinion

Resources

Title Description External URL

Morgan v. Sproat

Description of the Southern Poverty Law Center's recent involvement in the 1975 case Morgan v. Sproat. Aug. 1, 2003 https://www.splcenter.org/seeking-justice/case-docket/morgan-v-sproat

Docket

See docket on RECAP: https://www.courtlistener.com/docket/16214583/morgan-v-sproat/

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

ECF Number Description Date Link
1

Attached is a scanned copy of the original docket sheet. It will be necessary to review this docket sheet for complete information in this case, including attorneys of record, from filing through 2/10/2011. (Entered: 02/10/2011)

Feb. 4, 1975 PACER
2

MOTION to Substitute Attorney Kristen Levins. (cwl) (Entered: 02/10/2011)

Oct. 5, 2009 PACER

TEXT ONLY ORDER granting 2 Motion to Substitute Attorney. Attorney Kristen M. Levins terminated. Bear Atwood and Poonam Juneja substituted for Plaintiffs. No further written order will issue. Signed by Magistrate Judge Michael T. Parker on February 10, 2011 (KPM)

Feb. 10, 2011 PACER

Order on Motion to Substitute Attorney

Feb. 10, 2011 PACER
3

MOTION to Substitute Attorney by Ester K. Morgan (Owens, Jody) (Entered: 08/05/2011)

Aug. 5, 2011 PACER

Docket Annotation

Aug. 5, 2011 PACER
4

MOTION to Substitute Attorney by Ester K. Morgan (Owens, Jody) (Entered: 08/05/2011)

Aug. 5, 2011 PACER

DOCKET ANNOTATION as to # 3 incorrect signature date. See corrected document 4 . Motion 3 termed. (cwl)

Aug. 5, 2011 PACER

TEXT ONLY ORDER granting 4 Motion to Substitute Attorneys. Added attorney Sheila A. Bedi, Corrie Wynette Cockrell for Ester K. Morgan. Attorney Poonam Juneja, Danielle J. Lipow(PHV), Bear Hailey Atwood and Rhonda Brownstein (PHV) terminated. NO FURTHER WRITTEN ORDER WILL ISSUE. Signed by Magistrate Judge Michael T. Parker on August 9, 2011. (KM)

Aug. 9, 2011 PACER

Order on Motion to Substitute Attorney

Aug. 9, 2011 PACER
5

MOTION to Withdraw as Attorney by Ester K. Morgan (Bedi, Sheila) (Entered: 08/23/2012)

Aug. 23, 2012 PACER

TEXT ONLY ORDER granting 5 Motion to Withdraw as Attorney. Attorney Sheila A. Bedi terminated. NO FURTHER WRITTEN ORDER WILL ISSUE. Signed by Magistrate Judge Michael T. Parker on August 24, 2012 (KPM)

Aug. 24, 2012 PACER

Order on Motion to Withdraw as Attorney

Aug. 24, 2012 PACER
6

MOTION to Withdraw as Attorney by Ester K. Morgan (Cockrell, Corrie) (Entered: 06/26/2015)

June 26, 2015 PACER

Case Assigned/Reassigned

June 26, 2015 PACER

Case reassinged to Magistrate Judge Robert H. Walker. Magistrate Judge Michael T. Parker no longer assigned to the case. (cwl)

June 26, 2015 PACER

Order Reassigning Case

June 26, 2015 PACER

TEXT ONLY ORDER REASSIGNING CASE to Magistrate Judge Robert H. Walker, pursuant to Internal Rule 1, amended 2/2/15. NO FURTHER WRITTEN ORDER SHALL ISSUE FROM THIS COURT. Issued by District Judge Tom S. Lee on 6/26/15 (LWE) Modified on 6/30/2015 (LWE).

June 26, 2015 PACER

TEXT ONLY ORDER granting 6 Motion to Withdraw as Attorney. Attorney Corrie Wynette Cockrell terminated. No further written order will issue. Signed by Magistrate Judge Robert H. Walker on June 29, 2015. (King, Steve)

June 29, 2015 PACER

Order on Motion to Withdraw as Attorney

June 29, 2015 PACER
7

NOTICE of Appearance by Paloma Wu on behalf of All Plaintiffs (Wu, Paloma) (Entered: 09/18/2019)

Sept. 18, 2019 RECAP
8

MOTION to Withdraw as Attorney by Ester K. Morgan (Owens, Jody) (Entered: 09/18/2019)

Sept. 18, 2019 PACER

Order on Motion to Withdraw as Attorney

Sept. 24, 2019 PACER

TEXT ONLY ORDER granting 8 Motion to Withdraw as Attorney. Attorney Jody E. Owens, II terminated. No further written order will issue. Signed by Magistrate Judge Robert H. Walker on September 24, 2019 (King, Steve)

Sept. 24, 2019 PACER

State / Territory: Mississippi

Case Type(s):

Juvenile Institution

Key Dates

Filing Date: Feb. 4, 1975

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

All children who are now, or in the future will be, incarcerated in Oakley Training School, a juvenile training school in Mississippi, and all parents of these children.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Southern Poverty Law Center

ACLU Affiliates (any)

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Oakley Training School, State

Mississippi Department of Youth Services, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Availably Documents:

Trial Court Docket

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Litigation

Form of Settlement:

Court Approved Settlement or Consent Decree

Amount Defendant Pays: 26,462

Order Duration: 1975 - None

Content of Injunction:

Reporting

Issues

General:

Access to lawyers or judicial system

Confinement/isolation

Counseling

Disciplinary procedures

Education

Recreation / Exercise

Rehabilitation

Totality of conditions

Crowding:

Crowding / caseload

Affected Gender:

Male

Medical/Mental Health:

Dental care

Medical care, general

Type of Facility:

Government-run