Case: Hendrickson v. Griggs

3:84-03012 | U.S. District Court for the Northern District of Iowa

Filed Date: Feb. 2, 1984

Closed Date: May 23, 1991

Clearinghouse coding complete

Case Summary

In approximately 1984, a class of juveniles incarcerated at the Webster County Jail in Fort Dodge, Iowa, filed a lawsuit against county and state officials, on behalf of all juveniles who were or would be placed in the Jail by a juvenile court. The plaintiffs, represented by private counsel, brought the suit under 42 U.S.C. § 1983 and the Juvenile Justice Act, 42 U.S.C. §5601 and filed it in the U.S. District Court for the Northern District of Iowa. The plaintiffs alleged that, in violation o…

In approximately 1984, a class of juveniles incarcerated at the Webster County Jail in Fort Dodge, Iowa, filed a lawsuit against county and state officials, on behalf of all juveniles who were or would be placed in the Jail by a juvenile court. The plaintiffs, represented by private counsel, brought the suit under 42 U.S.C. § 1983 and the Juvenile Justice Act, 42 U.S.C. §5601 and filed it in the U.S. District Court for the Northern District of Iowa.

The plaintiffs alleged that, in violation of their constitutional rights to due process, the defendants failed to comply with certain provisions of the Juvenile Justice Act. Specifically, the plaintiffs sought compensatory, declaratory, and injunctive relief from the defendants' failure to implement policies respecting the deinstitutionalization of status offenders, the ban on regular contact between juveniles and incarcerated adults, and the jail removal mandate. The plaintiffs asked the court to forbid the defendants from permitting certain jailing practices, to prohibit the defendants from receiving or spending federal funds until they achieved compliance with the Juvenile Justice Act requirements, and to require the State to pay back any funds it had already received if it failed to adjust its policies.

The parties moved for summary judgment. On April 9, 1987, the court (Judge Donald E. O'Brien) denied the motions. The court, addressing the defendants' motions, found that the plaintiffs' claims were not barred because they could or should have been brought in juvenile court, that they were entitled to relief under the Juvenile Justice Act, that they did not need to proceed under a guardian ad litem, and that no indispensable party was excluded from the suit. In addition, the court barred the plaintiffs from seeking to cut off or pay back federal funds. Finally, the court ordered the defendants to present a plan describing policy changes to achieve reduced rates of juvenile jailing in compliance with the Juvenile Justice Act by April 30, 1987. Hendrickson v. Griggs, 672 F. Supp. 1126 (N.D. Iowa 1987).

The defendants submitted the plan for reducing the rate of juvenile confinement in adult facilities on May 4, 1987, and amended the plan on May 21, 1987.

The defendants appealed the district court's order to formulate a plan for dealing with the state's juvenile offenders. The U.S. Court of Appeals for the Eighth Circuit (Judge John R. Gibson) dismissed the appeal on September 1, 1988, for lack of jurisdiction. The court found the district court's order to be interlocutory and could not be appealed. Hendrickson v. Griggs, 856 F.2d 1041 (8th Cir. 1988).

On July 3, 1989, the plaintiffs filed a motion to dismiss the case because the State had achieved compliance with the Juvenile Justice Act requirements. The plaintiffs also renewed their motion for attorneys' fees and costs. On March 23, 1990, the district court (Judge O'Brien) awarded attorneys' fees to the plaintiffs as the prevailing parties and dismissed the action as moot. Hendrickson v. Branstad, 740 F. Supp. 636 (N.D. Iowa 1990).

The defendants appealed the district court's order awarding the plaintiffs attorneys' fees to the U.S. Court of Appeals for the Eighth Circuit. On May 23, 1991, the court (Judge C. Arlen Beam) affirmed in part and reversed in part; it found the plaintiffs to be the prevailing parties but reversed the district court's award of a 25% fee enhancement to be dropped. Hendrickson v. Branstad, 934 F.2d 158 (8th Cir. 1991).

The docket for the case is unavailable and therefore we have no further information on this case.

Summary Authors

Laura Uberti (6/25/2006)

Richard Jolly (10/14/2014)

People


Judge(s)

Bartels, John Ries (New York)

Beam, Clarence Arlen (Nebraska)

Gibson, John R. (Missouri)

O'Brien, Donald Eugene (Iowa)

Attorneys(s) for Plaintiff

Bird, John R. (Missouri)

Parker, Blake (Iowa)

Swanger, Harry F. (Missouri)

Attorneys(s) for Defendant

Allen, Gordon E. (Iowa)

Phillips, Charles K. (Iowa)

Salmons, Carlton G. (Iowa)

Judge(s)

Bartels, John Ries (New York)

Beam, Clarence Arlen (Nebraska)

Gibson, John R. (Missouri)

O'Brien, Donald Eugene (Iowa)

Attorneys(s) for Plaintiff

Bird, John R. (Missouri)

Parker, Blake (Iowa)

Swanger, Harry F. (Missouri)

Attorneys(s) for Defendant

Allen, Gordon E. (Iowa)

Phillips, Charles K. (Iowa)

Salmons, Carlton G. (Iowa)

Documents in the Clearinghouse

Document

3:84-03012

Reported Opinion

672 F.Supp. 1126

April 9, 1987

April 9, 1987

Order/Opinion

87-01860

Reported Opinion

U. S. Court of Appeals for the Eighth Circuit

856 F.2d 1041

Sept. 1, 1988

Sept. 1, 1988

Order/Opinion

3:84-03012

Order

Hendrickson v. Branstad

740 F.Supp. 636

March 23, 1990

March 23, 1990

Order/Opinion

90-01644

Reported Opinion

Hendrickson v. Branstad

U. S. Court of Appeals for the Eighth Circuit

934 F.2d 158

May 23, 1991

May 23, 1991

Order/Opinion

Resources

Docket

Last updated Aug. 10, 2022, 3 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Iowa

Case Type(s):

Jail Conditions

Key Dates

Filing Date: Feb. 2, 1984

Closing Date: May 23, 1991

Case Ongoing: No

Plaintiffs

Plaintiff Description:

All juveniles who were or would be placed at Webster County Jail by a juvenile court.

Public Interest Lawyer: No

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Webster County, Iowa (Fort Dodge, Webster), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Juvenile Justice Act, 42 U.S.C. § 5672

Constitutional Clause(s):

Due Process

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Litigation

Issues

General:

Access to lawyers or judicial system

Classification / placement

Affected Gender:

Female

Male

Type of Facility:

Government-run