Filed Date: Oct. 29, 2012
Case Ongoing
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On December 1, 2011, the Department of Justice Civil Rights Divisions launched an investigation of the Meridian Police Department and the Lauderdale County Youth Court pursuant to 42 U.S.C. § 14141 and 42 U.S.C. § 2000d. The DOJ expanded their investigation to include the Mississippi Division of Youth Services on June 29, 2012. On August 10, 2012, the DOJ published their findings that the agencies in question had violated the constitutional rights of the children under the Fourth, Fifth, and Fourteenth Amendments. The DOJ provided the agencies an opportunity to cure the offending behavior but no negotiations occurred.
On October 24, 2012, the United States filed a lawsuit against the agencies in the Southern District of Mississippi under 42 U.S.C. §14141. The government alleged that the defendants in the investigation collectively helped to operate a "school-to-prison pipeline." The government sought declaratory relief, an order permanently enjoining defendants from the alleged unlawful practices, an order requiring defendants to effectuate corrected polices, and other equitable relief.
This was the first lawsuit brought under a "school-to-prison pipeline" legal theory. Under this theory, the government claimed that the defendants systematically incarcerated children in Meridian for allegedly committing minor offenses and punished children disproportionately without due process. The government alleged that the Meridian Police Department would automatically arrest students referred by the Meridian Public School District without assessing the nature of the referral and without probable cause. Students were not provided adequate information regarding their rights. Students were then commonly held for more than 48 hours while they awaited youth court "detention hearings" that did not meet the Due Process requirement of the Constitution. These acts violated the constitutional rights of the children under the Fourth, Fifth, and Fourteenth Amendments.
On December 7, 2012, defendants filed a motion to dismiss based on Younger abstention. On September 4, 2013, United States District Judge Henry T. Wingate denied the motion. Judge Wingate noted 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 so as to justify barring prospective relief to a person not a party to the challenged state actions. The government may have interests that transcends that of private state defendants.
On December 26, 2013, the case was transferred to the Northern Division and assigned a new case number.
During 2014 and early 2015, the parties engaged in discovery and negotiated out of court. The negotiations culminated in a March 4, 2015 telephone conference in which the parties, except for the defendant judges and Lauderdale County, announced that they had reached a settlement. After reviewing the settlements, Judge Wingate issued two opinions on September 18, 2015. The first granted a motion for settlement between the United States and the City of Meridian. The second granted a motion for settlement between the United States and the State of Mississippi, the Mississippi Department of Human Services, and the Mississippi Division of Youth Services. See DOJ 15-768 (D.O.J.), 2015 WL 3809399. Defendant Lauderdale County and the two individual defendants, judges of the Lauderdale County Youth Court, were not parties to either of the settlements.
The first settlement focused on improving the conduct of the Meridian Police Department (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 12 consecutive months of "substantial compliance" by the City of Meridian. On March 18, 2016, the parties agreed on who should serve as Police Independent Auditor after a budget dispute, and Judge Wingate approved their choice on March 25, 2016.
The second settlement focused on improving the conduct of the Mississippi Division of Youth Services (DYS), which managed probation for youths. It required DYS to inform youths on probation of the probation process and their rights within it, limited the ability of DYS 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 12 consecutive months of "substantial compliance" by DYS. On January 5, 2016, the parties notified the court that they had agreed on the Probation Services Independent Auditor.
Meanwhile, the case against defendant Youth Court judges continued. The judges had moved to dismiss the claims against them on November 25, 2014. The court finally granted their motions on September 30, 2017. The judges argued that they were protected by judicial immunity and the Rooker-Feldman doctrine, which prevents parties that lost in state courts from re-litigating their claims in federal court. Judge Wingate found that the Rooker-Feldman doctrine did not apply because the United States did not seek to challenge a state court judgment against it. However, Judge Wingate granted defendants' motion under the theory of 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. The suit against Lauderdale County was 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 United States Court of Appeals for the Fifth Circuit. (Docket No. 17-60805). The Fifth Circuit finally issued an opinion on February 1, 2019, where it affirmed the district court. 914 F.3d 960. The case was subsequently dismissed.
In the meantime, 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 final report which stated that the City of Meridian and the Meridian Police Department 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 United States. The United States submitted its first compliance report on September 12, 2018, which found that the City of Meridian and its police 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 was not in substantial compliance with the 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 defendant Youth Court judges refused access to Youth Court files, possibly due to the continuing litigation against them. Both settlement agreements continued to be monitored.
On May 23, 2019, the parties filed a joint motion to terminate the first settlement, which governs MPD and Meridian public schools, on account of substantial compliance for 12 consecutive months. As of June 8, 2020, monitoring continues and the parties are awaiting a motion hearing on the motion to terminate.
Summary Authors
Richard Jolly (11/18/2014)
Timothy Leake (10/18/2018)
Alex Moody (4/20/2020)
Jack Hibbard (6/8/2020)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/7863902/parties/united-states-v-city-of-meridian/
Anderson, Linda Randle (Mississippi)
Austin, Roy L. (District of Columbia)
Cuncannan, Jacqueline (District of Columbia)
Bailey, Robert Thomas (Mississippi)
Darsey, Reed C. (Mississippi)
Anderson, Linda Randle (Mississippi)
Elrod, Jennifer Walker (Texas)
Wingate, Henry Travillion (Mississippi)
Austin, Roy L. (District of Columbia)
Cuncannan, Jacqueline (District of Columbia)
Davis, Gregory K. (Mississippi)
Dreiband, Eric S. (District of Columbia)
Goemann, Richard C. (District of Columbia)
Gupta, Vanita (District of Columbia)
Hurst, D Michael (Mississippi)
Jackson, Shelley (District of Columbia)
Jernigan, Alfred B. Jr. (Mississippi)
Jones, Michelle A. (District of Columbia)
Kappelhoff, Mark (District of Columbia)
Ogletree, Rashida J (District of Columbia)
Paige, Mitzi Dease (Mississippi)
Perez, Thomas E. (District of Columbia)
Porter, Forestine Nicole (District of Columbia)
Preston, Judy C. (District of Columbia)
Rifkin, Lori Ellen (District of Columbia)
See docket on RECAP: https://www.courtlistener.com/docket/7863902/united-states-v-city-of-meridian/
Last updated Feb. 23, 2024, 3:16 a.m.
State / Territory: Mississippi
Case Type(s):
Special Collection(s):
Key Dates
Filing Date: Oct. 29, 2012
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
The Department of Justice Civil Rights Division, on behalf of youths arrested, tried, and detained in Lauderdale County, Mississippi.
Plaintiff Type(s):
U.S. Dept of Justice plaintiff
Attorney Organizations:
U.S. Dept. of Justice Civil Rights Division
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
City of Meridian (Lauderdale), City
County of Lauderdale (Lauderdale), County
Lauderdale County Youth Center (Lauderdale), County
Mississippi Department of Human Services, State
Mississippi Division of Youth Services, State
Named Judges (Meridian, Lauderdale), None
Defendant Type(s):
Case Details
Causes of Action:
Violent Crime and Law Enforcement Act, 34 U.S.C. § 12601 (previously 42 U.S.C. § 14141)
Title VI, Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.
Constitutional Clause(s):
Unreasonable search and seizure
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Order Duration: 2015 - None
Issues
General:
Access to lawyers or judicial system
Discrimination-area:
Type of Facility: