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Case Name Coleman v. Stanziani JI-PA-0002
Docket / Court 81-2215 ( E.D. Pa. )
State/Territory Pennsylvania
Case Type(s) Juvenile Institution
Attorney Organization Legal Services/Legal Aid
Case Summary
In approximately 1981, juveniles who had been detained in Pennsylvania juvenile facilities prior to a disposition hearing filed a class action lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Eastern District of Pennsylvania against Juvenile Court judges, a juvenile probation ... read more >
In approximately 1981, juveniles who had been detained in Pennsylvania juvenile facilities prior to a disposition hearing filed a class action lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the Eastern District of Pennsylvania against Juvenile Court judges, a juvenile probation officer, the Juvenile Court, and Montgomery County, Pennsylvania. The plaintiffs sought declaratory and injunctive relief challenging the constitutionality of the "preventive detention" provisions of the Pennsylvania Juvenile Act. The Juvenile Law Center of Philadelphia represented the plaintiff class. Both a plaintiff and a defendant class were certified. The plaintiff class, certified on May 20, 1982, included all juveniles who were then, or would be detained prior to a disposition hearing pursuant to the challenged statutes. The defendant class included all Juvenile Court Judges, Masters, and probation officers who were then, or would be responsible for conducting preventive detention under the challenged statutes.

The relevant provisions of the challenged statutes provided for detention of juveniles prior to adjudication or disposition where "detention or care is required to protect the person or property of others or of the child or because the child may abscond or be removed from the jurisdiction of the court ..." 42 PA. CONS. STAT. ANN. § 6325. See also 42 PA. CONS. STAT. ANN. §§ 6335, 6341. The plaintiffs were challenging the standards and procedures by which they were detained.

On September 14, 1983, the District Court (Judge Joseph S. Lord, III) denied the defendants motion for judgment on the pleadings and partial decertification of the plaintiff's class. Coleman v. Stanziani, 570 F. Supp. 679 (E.D.Pa. 1983). The U.S. Court of Appeals, Third Circuit (Judge John Joseph Gibbons) dismissed the appeal, because (1) the appeal was interlocutory, and (2) the writ of mandamus sought was inappropriate. Stanziani v. Coleman, 735 F.2d 118 (3d Cir. 1984). The Supreme Court denied the petition for writ of certiorari. Stanziani v. Coleman, 469 U.S. 1037 (1984).

On April 18, 1986, the District Court (Judge Lord) entered a consent decree, which took effect on September 1, 1986. The consent decree named the Juvenile Court Judges' Commission as the monitor, and was to be in effect for ten years from the date of approval. The consent decree provided that juveniles could only be placed in secure detention prior to adjudication or disposition when security is shown to be necessary. Pre-adjudication detention could not be used as a means of punishment. Detention prior to adjudication was allowed where it was required to protect the person or property of others or the juvenile, or where it was required because the child may leave or be removed from the jurisdiction. Detention prior to disposition was allowed where the offense was one for which detention could be authorized, where the juvenile was initially detained, where placement is probable, and where the juvenile may leave the jurisdiction if not detained. Detention after disposition was entered, but prior to its implementation was allowed for the same reasons as detention prior to disposition. Detention was also allowed for extraordinary and exceptional circumstances. The consent decree also required specific procedures to be followed when determining whether pre-adjudication or pre-disposition detention was appropriate, and procedures to be followed after the detention decision was made.

The District Court modified the consent decree on December 15, 1986, to clarify when administrative reviews were required. Administrative reviews were required in all cases of children in secure detention after a disposition order had been entered but before it was implemented, and pending disposition review proceedings or while awaiting a disposition order.

We have no further information about this case.

Kaitlin Corkran - 05/23/2006


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Issues and Causes of Action
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Issues
General
Access to lawyers or judicial system
Classification / placement
Disciplinary procedures
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) All Secure Detention Facilities in Pennsylvania
Juvenile Court and Montgomery County
Plaintiff Description All juveniles who were or would be detained prior to a disposition hearing pursuant to the Pennsylvania statutes challenged.
Indexed Lawyer Organizations Legal Services/Legal Aid
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1986 - 1996
Case Closing Year 1996
Case Ongoing No
Docket(s)
No docket sheet currently in the collection
General Documents
Opinion 09/14/1983 (570 F.Supp. 679) (E.D. Pa.)
JI-PA-0002-0004.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion of the Court 06/04/1984 (735 F.2d 118)
JI-PA-0002-0005.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Memorandum Decision 11/26/1984 (469 U.S. 1037)
JI-PA-0002-0006.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Order 04/18/1986 (E.D. Pa.)
JI-PA-0002-0001.pdf | Detail
Order 12/15/1986 (E.D. Pa.)
JI-PA-0002-0002.pdf | Detail
Consent Decree 12/15/1986 (E.D. Pa.)
JI-PA-0002-0003.pdf | Detail
Judges Gibbons, John Joseph (Third Circuit)
JI-PA-0002-0005
Lord, Joseph Simon III (E.D. Pa.)
JI-PA-0002-0001 | JI-PA-0002-0002 | JI-PA-0002-0003 | JI-PA-0002-0004
Monitors/Masters None on record
Plaintiff's Lawyers Bird, John R. (Missouri)
JI-PA-0002-0004 | JI-PA-0002-0005
Schall, Lawrence M. (Pennsylvania)
JI-PA-0002-0003 | JI-PA-0002-0004 | JI-PA-0002-0005
Schwartz, Robert G. (Pennsylvania)
JI-PA-0002-0005
Swanger, Harry F. (Missouri)
JI-PA-0002-0004 | JI-PA-0002-0005
Defendant's Lawyers Abramson, Howland W. (Pennsylvania)
JI-PA-0002-0003 | JI-PA-0002-0004 | JI-PA-0002-0005
Donaldson, David M. (Pennsylvania)
JI-PA-0002-0005
Gordon, Andrew S. (Pennsylvania)
JI-PA-0002-0005
Jenkins, Walter (Pennsylvania)
JI-PA-0002-0003 | JI-PA-0002-0005
McGrath, Kathleen F. (Pennsylvania)
JI-PA-0002-0004 | JI-PA-0002-0005
Warshaw, Allen C. (Pennsylvania)
JI-PA-0002-0005
Other Lawyers None on record

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