University of Michigan Law School
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Case Name Morgan v. Sproat JI-MS-0003
Docket / Court J75-21 ( S.D. Miss. )
State/Territory Mississippi
Case Type(s) Juvenile Institution
Case Summary
On or about 1975, juveniles at the Oakley Training School (OTS), a Mississippi state institution for delinquent boys, filed a class action lawsuit against the Department of Youth Services in the United States District Court for the Southern District of Mississippi pursuant to 42 U.S.C. § 1983. ... read more >
On or about 1975, juveniles at the Oakley Training School (OTS), a Mississippi state institution for delinquent boys, filed a class action lawsuit against the Department of Youth Services in the United States District Court for the Southern District of Mississippi pursuant to 42 U.S.C. § 1983. The plaintiffs, represented by private counsel, alleged that the institution did not fulfill its intended purpose to rehabilitate youth and that the conditions at the institution violated their constitutional rights. The plaintiffs alleged that they were punished by being placed in intensive treatment units where they were isolated for extended periods of time and that counseling programs, medical care, and legal services were all unconstitutionally deficient. Because of these alleged violations, plaintiffs sought injunctive relief.

On April 1, 1975, the district court (Judge Walter Nixon) certified the case as a class action of all present and future students confined at OTS, which at the time of filing consisted of 350 boys between the ages of 15 and 20. On November 22, 1975, the court entered an agreed order relating to discipline procedures. Under the order, defendants agreed to provide procedural safeguards, including prior notice and an impartial evidentiary hearing, to all OTS students accused of violating school rules and regulations. Defendants also promulgated a new code of rules, which was adopted by the court on November 26, 1976.

On April 18, 1977, the district court (Judge Nixon) found that the policies in place at OTS violated plaintiffs' constitutional rights. Morgan v. Sproat, 432 F.Supp. 1130 (S.D. Miss. 1977). First, the court held the plaintiffs' due process rights were being violated, because the adjudication procedure used to commit juveniles to the state institution were developed with the intention that it be a therapeutic rather than punitive incarceration; therefore, by the acts of defendants, plaintiffs were being sent to a punitive state facility without due process for such punishment. Second, the court found that the conditions at the institution violated the juveniles' Eighth Amendment rights. The court ordered that defendants were enjoined from placing juveniles in intensive treatment units except when they posed an immediate threat, and then for no more than twenty-four hours. The court further ordered that defendants develop educational, vocational, and recreational programming to meet the needs of the juveniles. Defendants were also ordered to address overcrowding issues at the facility as well as increase access to dental and medical care. Finally, the court ordered that defendants forward requests by juveniles for legal representation to a legal services program. There is no PACER docket available for this case, and we have no further information.

Emilee Baker - 05/16/2006


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Issues and Causes of Action
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Issues
Affected Gender
Male
Crowding
Crowding / caseload
General
Access to lawyers or judicial system
Confinement/isolation
Counseling
Disciplinary procedures
Education
Recreation / Exercise
Rehabilitation
Totality of conditions
Medical/Mental Health
Dental care
Medical care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Department of Youth Services
Oakley Training School
Plaintiff Description All present and future students at Oakley Training School
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer No
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1975 - n/a
Case Closing Year n/a
Case Ongoing Unknown
Docket(s)
No docket sheet currently in the collection
General Documents
Memorandum Opinion 04/18/1977 (432 F.Supp. 1130) (S.D. Miss.)
JI-MS-0003-0002 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Nixon, Walter Louis Jr. (S.D. Miss.)
JI-MS-0003-0002
Monitors/Masters None on record
Plaintiff's Lawyers Powell, Barry H. (Mississippi)
JI-MS-0003-0002
Ramberg, Charles H. (Mississippi)
JI-MS-0003-0002
Defendant's Lawyers Googe, P. Roger Jr. (Mississippi)
JI-MS-0003-0002
Other Lawyers None on record

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