Case: Coleman v. Stanziani

2:81-02215 | U.S. District Court for the Eastern District of Pennsylvania

Filed Date: May 29, 1981

Closed Date: Dec. 15, 1996

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Case Summary

In approximately 1981, juveniles who had been detained in Pennsylvania juvenile facilities prior to a disposition hearing filed a class action lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Eastern District of Pennsylvania against Juvenile Court judges, a juvenile probation officer, the Juvenile Court, and Montgomery County, Pennsylvania. The plaintiffs sought declaratory and injunctive relief challenging the constitutionality of the "preventive detention" provisions of the P…

In approximately 1981, juveniles who had been detained in Pennsylvania juvenile facilities prior to a disposition hearing filed a class action lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Eastern District of Pennsylvania against Juvenile Court judges, a juvenile probation officer, the Juvenile Court, and Montgomery County, Pennsylvania. The plaintiffs sought declaratory and injunctive relief challenging the constitutionality of the "preventive detention" provisions of the Pennsylvania Juvenile Act. The Juvenile Law Center of Philadelphia represented the plaintiff class. Both a plaintiff and a defendant class were certified. The plaintiff class, certified on May 20, 1982, included all juveniles who were then, or would be detained prior to a disposition hearing pursuant to the challenged statutes. The defendant class included all Juvenile Court Judges, Masters, and probation officers who were then, or would be responsible for conducting preventive detention under the challenged statutes.

The relevant provisions of the challenged statutes provided for detention of juveniles prior to adjudication or disposition where "detention or care is required to protect the person or property of others or of the child or because the child may abscond or be removed from the jurisdiction of the court ..." 42 PA. CONS. STAT. ANN. § 6325. See also 42 PA. CONS. STAT. ANN. §§ 6335, 6341. The plaintiffs were challenging the standards and procedures by which they were detained.

On September 14, 1983, the District Court (Judge Joseph S. Lord, III) denied the defendants motion for judgment on the pleadings and partial decertification of the plaintiff's class. Coleman v. Stanziani, 570 F. Supp. 679 (E.D.Pa. 1983). The U.S. Court of Appeals, Third Circuit (Judge John Joseph Gibbons) dismissed the appeal, because (1) the appeal was interlocutory, and (2) the writ of mandamus sought was inappropriate. Stanziani v. Coleman, 735 F.2d 118 (3d Cir. 1984). The Supreme Court denied the petition for writ of certiorari. Stanziani v. Coleman, 469 U.S. 1037 (1984).

On April 18, 1986, the District Court (Judge Lord) entered a consent decree, which took effect on September 1, 1986. The consent decree named the Juvenile Court Judges' Commission as the monitor, and was to be in effect for ten years from the date of approval. The consent decree provided that juveniles could only be placed in secure detention prior to adjudication or disposition when security is shown to be necessary. Pre-adjudication detention could not be used as a means of punishment. Detention prior to adjudication was allowed where it was required to protect the person or property of others or the juvenile, or where it was required because the child may leave or be removed from the jurisdiction. Detention prior to disposition was allowed where the offense was one for which detention could be authorized, where the juvenile was initially detained, where placement is probable, and where the juvenile may leave the jurisdiction if not detained. Detention after disposition was entered, but prior to its implementation was allowed for the same reasons as detention prior to disposition. Detention was also allowed for extraordinary and exceptional circumstances. The consent decree also required specific procedures to be followed when determining whether pre-adjudication or pre-disposition detention was appropriate, and procedures to be followed after the detention decision was made.

The District Court modified the consent decree on December 15, 1986, to clarify when administrative reviews were required. Administrative reviews were required in all cases of children in secure detention after a disposition order had been entered but before it was implemented, and pending disposition review proceedings or while awaiting a disposition order.

We have no further information about this case.

Summary Authors

Kaitlin Corkran (5/23/2006)

People


Judge(s)

Gibbons, John Joseph (Pennsylvania)

Lord, Joseph Simon III (Pennsylvania)

Attorneys(s) for Plaintiff

Bird, John R. (Missouri)

Schall, Lawrence M. (Pennsylvania)

Schwartz, Robert G. (Pennsylvania)

Swanger, Harry F. (Missouri)

Attorneys(s) for Defendant

Abramson, Howland W. (Pennsylvania)

Donaldson, David M. (Pennsylvania)

Gordon, Andrew S. (Pennsylvania)

Jenkins, Walter (Pennsylvania)

Judge(s)

Gibbons, John Joseph (Pennsylvania)

Lord, Joseph Simon III (Pennsylvania)

Attorneys(s) for Plaintiff

Bird, John R. (Missouri)

Schall, Lawrence M. (Pennsylvania)

Schwartz, Robert G. (Pennsylvania)

Swanger, Harry F. (Missouri)

Attorneys(s) for Defendant

Abramson, Howland W. (Pennsylvania)

Donaldson, David M. (Pennsylvania)

Gordon, Andrew S. (Pennsylvania)

Jenkins, Walter (Pennsylvania)

McGrath, Kathleen F. (Pennsylvania)

Warshaw, Allen C. (Pennsylvania)

Documents in the Clearinghouse

Document

Opinion

570 F.Supp. 679

Sept. 14, 1983 Order/Opinion

Opinion of the Court

U. S. Court of Appeals for the Third Circuit

735 F.2d 118

June 4, 1984 Order/Opinion

Memorandum Decision

Stanziani v. Coleman

Supreme Court of the United States

469 U.S. 1037, 105 S.Ct. 515, 83 L.Ed.2d 404

Nov. 26, 1984 Order/Opinion

Order

April 18, 1986 Order/Opinion

Consent Decree

Dec. 15, 1986 Order/Opinion

Order

Dec. 15, 1986 Order/Opinion

Resources

Title Description External URL

Coleman v. Stanziani

Juvenile Law Center

In 1981, Juvenile Law Center filed a civil rights class action lawsuit in federal court challenging Pennsylvania law and practices that governed the detention of youth charged with committing delinqu… July 8, 1981 https://jlc.org/cases/coleman-v-stanziani

Secure Detention in Pennsylvania, 1981-1990: The Experience after Coleman v. Stanziani

James E. Anderson and Robert G. Schwartz

https://books.google.com/books?id=hbl47NYkXvoC&pg=PA128&lpg=PA128&dq=Coleman+v.+Stanziani&source=bl&ots=C2Cf1_8zvY&sig=ACfU3U1MTooqddr4hfG5dGTCuZxwHi93dA&hl=en&sa=X&ved=2ahUKEwj5vO-0nvjqAhXVZc0KHQGZD7kQ6AEwB3oECAoQAQ#v=onepage&q=Coleman%20v.%20Stanzi

Docket

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

Docket sheet not available via the Clearinghouse.

State / Territory: Pennsylvania

Case Type(s):

Juvenile Institution

Key Dates

Filing Date: May 29, 1981

Closing Date: Dec. 15, 1996

Case Ongoing: No

Plaintiffs

Plaintiff Description:

All juveniles who were or would be detained prior to a disposition hearing pursuant to the Pennsylvania statutes challenged.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Legal Services/Legal Aid

Juvenile Law Center

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Juvenile Court and Montgomery County, County

All Secure Detention Facilities in Pennsylvania, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Due Process

Due Process: Substantive Due Process

Availably Documents:

Injunctive (or Injunctive-like) Relief

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1986 - 1996

Issues

General:

Access to lawyers or judicial system

Classification / placement

Disciplinary procedures

Type of Facility:

Government-run