On September 21, 2016, six named plaintiffs filed this class action lawsuit against Onondaga County in the U.S. District Court for the Northern District of New York. Represented by the New York Civil Liberties Union Foundation and Legal Services of Central New York, the plaintiffs challenged the isolation of juveniles in solitary confinement at the County Justice Center. This practice, they alleged, violated the Eighth and Fourteenth Amendments of the Constitution. In addition to exposing them to serious harm, plaintiffs subclass members claimed the Onondaga Sherriff’s Office and Syracuse City School District denied them basic education and services under the Individuals with Disabilities Education Act (IDEA). The plaintiffs sought declaratory, injunctive, and monetary relief, as well as class action certification.
On January 2, 2017, the Civil Rights Division of the U.S. Department of Justice filed a statement of interest regarding the plaintiff’s motion for preliminary injunction. Citing both scientific findings and case law, the DOJ emphasized the greater psychological vulnerability of juveniles compared to adults. Specifically, the DOJ pointed to evidence that isolating juveniles causes serious harm.
This case was assigned to U.S. District Judge David N. Hurd. On February 22, 2017, Judge Hurd held the plaintiffs had complied with Rule 23’s requirements for class certification and demonstrated a substantial likelihood of success on the merits of their claims. Judge Hurd therefore, granted the plaintiffs’ motion for class certification and denied the defendants’ motion for summary judgment. The certified class was composed of 16- and 17-year-olds being detained at the Onondaga County Justice Center. He also ordered that defendants be immediately enjoined and restrained from imposing 23-hour disciplinary isolation. Judge Hurd further granted the plaintiffs’ motion for preliminary injunction and ordered that defendants immediately provide juveniles the proper education mandated under New York law, and specifically comply with the special education requirements under the IDEA. Finally, he ordered that all imposed discipline include meaningful social interaction with other and not directly harm a juvenile’s psychological condition.
On April 10, 2017, Judge Hurd approved the parties’ joint stipulation and order for an interim settlement agreement. On August 28, 2017, he approved the final settlement agreement. The settlement agreement prohibited any juvenile from being locked in solitary confinement unless the juvenile posed an imminent threat to the safety and security of the facility, and placed time limitations on how long the juvenile could be kept in solitary confinement. The settlement also prescribed procedures for staff to take to minimize and periodically reassess the circumstances requiring solitary confinement. Furthermore, the defendants were required to implement a comprehensive behavior management system and apply a least-restrictive sanctions system. Defendants were also required to provide certain education opportunities to the juveniles, especially those with a disability. Lastly, the settlement included reporting and monitoring procedures to ensure that the defendants adhered to the settlement conditions. The parties were to engage in good-faith negotiations over reasonable attorneys’ fees and costs for plaintiffs’ counsel after court approval of the settlement agreement.
The settlement was made court-enforceable, and was set to last until October 1, 2019, or until all juveniles were moved out of the relevant facility, whichever came last.
On December 13, 2017, the settlement was entered after the parties did not receive any class-member objections to the settlement agreement. No enforcement activity appears in the docket. On October 31, 2019, the parties notified the Court that all juveniles had been transferred out; the Court accordingly closed the case on November 8, 2019.
Amanda Grill - 01/22/2017
Lisa Limb - 03/22/2019
compress summary
