Filed Date: Sept. 6, 1978
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A class of juveniles represented by Legal Services of Eastern Missouri filed a lawsuit in 1978 under 42 U.S.C. § 1983 in the U.S. District Court for the Eastern District of Missouri, against state judges, state juvenile officers, and county sheriffs, alleging unconstitutional conditions of confinement in the St. Charles, Pike, and Lincoln County jails and denial of their constitutional rights when they were confined without probable cause hearings. The issue of conditions of confinement was settled by the parties in a consent decree entered by the court on July 31, 1980, which barred the incarceration of juveniles in the St. Charles or Pike County jails. The court found for the juveniles on the probable cause issue. On June 17, 1982, in a hearing on a motion to reconsider on the issue of attorney's fees, the court (Judge Edward L. Filippine) held that fees assessed against state defendants could be paid from state funds; judicial immunity did not bar an award of fees against state judges; and that the county sheriff was not liable for fees. R.W.T. v. Dalton, 540 F. Supp. 772 (E.D.Mo. 1982).
The U.S. Court of Appeals for the Eighth Circuit (Judge Richard Sheppard Arnold) affirmed in part and reversed in part, finding that juveniles are entitled under the Fourth and Fourteenth Amendments to probable cause hearings, regardless of whether the juvenile is a criminal or non-criminal, status offender; the judges were not proper defendants in the suit; juvenile officers are not immune from suit; injunctive relief was not improper; and that the state was liable for one half of juveniles' attorney fees. R.W.T. v. Dalton, 712 F.2d 1225 (8th Cir. 1983). On December 5, 1983, the United Stated Supreme Court denied certiorari. Dalton v. R.W.T., 104 S.Ct. 527 (1983).
Summary Authors
Megan Raynor (3/25/2006)
Arnold, Richard Sheppard (Arkansas)
Ashcroft, John (District of Columbia)
Cohn, Kenneth A. (Missouri)
Davis, E. Darrell Jr. (Missouri)
Dietrich, Thomas W. (Missouri)
Arnold, Richard Sheppard (Arkansas)
Filippine, Edward Louis (Missouri)
Last updated April 4, 2024, 3:01 a.m.
Docket sheet not available via the Clearinghouse.State / Territory: Missouri
Case Type(s):
Key Dates
Filing Date: Sept. 6, 1978
Case Ongoing: No
Plaintiffs
Plaintiff Description:
Juveniles who have been, are, or may be detained in jails or detention centers by juvenile authorities in the Eleventh Judicial Circuit of the State of Missouri (St. Charles, Lincoln, Pike Counties)
Attorney Organizations:
NDRN/Protection & Advocacy Organizations
Public Interest Lawyer: Yes
Filed Pro Se: Unknown
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
Judges and Associate Judges of Eleventh Judicial Circuit of State of Missouir, State
Judges of County Court for St. Charles County, County
Sheriffs of St. Charles, Lincoln, and Pike Counties, County
Juvenile Office and Deputy Juvenile Officer of Eleventh Judicial Circuit of State of Missouri, State
Pike County Jail (Pike), County
St. Charles County Jai (St. Charles, St. Charles), County
Case Details
Causes of Action:
Constitutional Clause(s):
Due Process: Substantive Due Process
Unreasonable search and seizure
Available Documents:
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: 1980 - None
Issues
General:
Sanitation / living conditions
Type of Facility: