University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Jerry M. v. District of Columbia JC-DC-0003
Docket / Court 1519-85 ( State Court )
State/Territory District of Columbia
Case Type(s) Jail Conditions
Juvenile Institution
Special Collection Court-ordered receiverships
Case Summary
On March 1, 1985, a class of juveniles confined at juvenile detention centers operated by the District of Columbia ("the District") filed a lawsuit against the District under 42 U.S.C. § 1983, in the Superior Court of the District of Columbia. They alleged unconstitutional conditions of ... read more >
On March 1, 1985, a class of juveniles confined at juvenile detention centers operated by the District of Columbia ("the District") filed a lawsuit against the District under 42 U.S.C. § 1983, in the Superior Court of the District of Columbia. They alleged unconstitutional conditions of confinement in violation of the juveniles' Fifth and Eighth Amendment rights. Plaintiffs specifically challenged the conditions of confinement at Cedar Knoll Youth Center and Oak Hill Youth Center, both in Laurel, Maryland, alleging that the facilities at Cedar Knoll were unfit for habitation and that rehabilitative services, including educational and vocational training services, mental health and medical services, and social and recreational services, were unconstitutionally and statutorily inadequate at both Centers. The complaint further alleged that a climate of violence existed at both Centers, and that policies concerning attorney-client communication and family visitation at both Centers violated the juveniles' rights. The plaintiffs, represented by the Public Defender Service and the ACLU National Prison Project, sought declaratory and injunctive relief.

On July 24, 1986, the Superior Court (Honorable Ricardo M. Urbina) approved and entered a consent decree ("the Decree"). The consent decree established a panel of three experts to determine the correct number of juveniles in the District in need of secure confinement, and develop a system for appropriate care of these juveniles. The Decree established procedural rules for staff discipline and training, recordkeeping, and discipline of juveniles; set forth detailed requirements for diagnostic procedures, cottage life, recreational, mental health, and social services, as well as education and vocational training programs; and required the District to submit a plan and timetable for resolving environmental health and safety concerns.

We have only appellate decisions describing subsequent litigation, but it is clear that extensive litigation over the scope of the Decree followed. Following the panel's submission of a plan to the court, and the court's orders pursuant to this plan, the District appealed. The District of Columbia Court of Appeals (Chief Judge Rogers) found that the trial judge had exceeded his authority under the scope of the decree in certain respects. Jerry M. v. District of Columbia, 571 A.2d 178 (D.C. Ct. App. 1990). The court of appeals did, however, find that the trial judge had not erred in finding that the District had, "failed to meet its basic commitment under the Decree," and imposing sanctions.

On September 5, 1990, the D.C. Court of Appeals (Judge Farrell) affirmed the lower court's ruling that plaintiffs' attorneys could be awarded fees for their work enforcing the Decree, but remanded the issue to the trial court because the it had failed to adequately explain its reasoning as to the amount of fees awarded. District of Columbia v. Jerry M., 580 A.2d 1270 (D.C. Ct. App. 1990). Attorney's fees litigation continued over several years. In 1996, the plaintiffs' attorney submitted a bill for work done during the months of April, May, and June, 1996. Defendants contested, arguing that fees for any work done after passage of the Prison Litigation Reform Act ("PLRA") were subject to the PLRA fee cap; the District Court (Judge Richard A. Levie) held that the PLRA did not apply to juvenile facilities, but on September 3, 1998, the D.C. Court of Appeals (Judge Schwelb) reversed, and held that the PLRA's limitation on attorney fee awards did apply to attorneys whose clients were confined juveniles, and that the fee cap did not violate due process. District of Columbia v. Jerry M., 717 A.2d 866 (D.C. 1998).

Meanwhile, on June 24, 1997, the U.S. District Court for the District of Columbia appointed a Special Master to assist the defendants "in identifying and correcting deficiencies in the provision of educational services required by the Consent Decree," because the defendants had repeatedly failed to bring the educational systems at the Centers into compliance with the Decree. In August, 1998, the Special Master expressed concern over "certain personnel, resource, and training issues" at the Oak Hill Center, and the trial court appointed a receiver "to assume, ëultimate control over the education system at Oak Hill.'" The District appealed, and the D.C. Court of Appeals (per curiam) held that, while the District had not fully complied with the Decree, there was not a sufficient basis for the imposition of such an extraordinary remedy. District of Columbia v. Jerry M., 738 A.2d 1206 (D.C. 1999). On May 15, 2000, the United States Supreme Court denied certiorari. Jerry M. v. District of Columbia, 529 U.S. 1118 (2000).

Megan Raynor - 04/17/2006
Maurice Youkanna - 06/26/2014


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Issues and Causes of Action
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Issues
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Content of Injunction
Hire
Monitoring
Recordkeeping
Reporting
Defendant-type
Corrections
Disability
disability, unspecified
Mental impairment
General
Access to lawyers or judicial system
Assault/abuse by residents/inmates/students
Conditions of confinement
Counseling
Disciplinary procedures
Education
Juveniles
Recreation / Exercise
Rehabilitation
Restraints : physical
Sanitation / living conditions
Special education
Totality of conditions
Transportation
Unconstitutional conditions of confinement
Visiting
Medical/Mental Health
Medical care, general
Medical care, unspecified
Mental health care, general
Mental health care, unspecified
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action Declaratory Judgment Act, 28 U.S.C. § 2201
42 U.S.C. § 1983
State law
Defendant(s) District of Columbia
District of Columbia
District of Columbia
Plaintiff Description detained and committed children confined in juvenile facilities in the District of Columbia
Indexed Lawyer Organizations None on record
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 - n/a
Case Closing Year 2000
Case Ongoing No
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
No docket sheet currently in the collection
General Documents
Complaint 03/01/1985
JC-DC-0003-0001 PDF | Detail
Amended Complaint 01/15/1986
JC-DC-0003-0002 PDF | Detail
Motion to Amend the Complaint and Incorporated Memorandum of points and Authorities 04/01/1986
JC-DC-0003-0004 PDF | Detail
Consent Decree 07/24/1986
JC-DC-0003-0003 PDF | Detail
Opinion [Finding District in Contempt; Limiting Consent Decree] 02/12/1990 (571 A.2d 178)
JC-DC-0003-0006 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion [Re: Fees] 09/05/1990 (580 A.2d 1270)
JC-DC-0003-0007 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion [Re: Fees] 09/03/1998 (717 A.2d 866)
JC-DC-0003-0008 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion [Vacating Appointment of Receiver] 09/30/1999 (738 A.2d 1206)
JC-DC-0003-0005 PDF | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Memorandum Decision [Denying Cert. to CtApp] 05/15/2000 (529 U.S. 1118)
JC-DC-0003-0009 PDF | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judges Farrell, Michael W. (State Supreme Court)
JC-DC-0003-0007
Kern, John W. III (State Appellate Court)
JC-DC-0003-0005
Rogers, Judith Ann Wilson (D.C. Circuit)
JC-DC-0003-0006
Schwelb, Frank E. (State Supreme Court)
JC-DC-0003-0008
Terry, John A. (State Appellate Court)
JC-DC-0003-0005
Urbina, Ricardo M. (D.D.C.)
JC-DC-0003-0003
Wagner, Anice M. (State Supreme Court)
JC-DC-0003-0005
Monitors/Masters Beyer, Margaret (District of Columbia)
JC-DC-0003-0003
DeMuro, Paul (New Jersey)
JC-DC-0003-0003 | JC-DC-0003-0003 | JC-DC-0003-0003
Lewis, Michael P. (District of Columbia)
JC-DC-0003-0003
Plaintiff's Lawyers Carter, Francis D (District of Columbia)
JC-DC-0003-0001
Hertz, Randy (District of Columbia)
JC-DC-0003-0001
Klein, James W. (District of Columbia)
JC-DC-0003-0005 | JC-DC-0003-0006 | JC-DC-0003-0007 | JC-DC-0003-0008
Long, Cheryl M. (District of Columbia)
JC-DC-0003-0002 | JC-DC-0003-0003 | JC-DC-0003-0004
McClymont, Mary E. (District of Columbia)
JC-DC-0003-0002 | JC-DC-0003-0003 | JC-DC-0003-0004
Ney, Steven (Maryland)
JC-DC-0003-0002 | JC-DC-0003-0003 | JC-DC-0003-0004
Ogletree, Charles J. (District of Columbia)
JC-DC-0003-0001
Pendry, Reita (District of Columbia)
JC-DC-0003-0001
Reiser, David A. (District of Columbia)
JC-DC-0003-0005 | JC-DC-0003-0006 | JC-DC-0003-0007 | JC-DC-0003-0008
Sonenberg, Santha (District of Columbia)
JC-DC-0003-0002 | JC-DC-0003-0003 | JC-DC-0003-0004
Stone, Randolph N. (District of Columbia)
JC-DC-0003-0002 | JC-DC-0003-0003 | JC-DC-0003-0004
Taylor, Kim A. (District of Columbia)
JC-DC-0003-0006 | JC-DC-0003-0007
Wilkins, Robert Leon (District of Columbia)
JC-DC-0003-0005
Wulkan, Donna (District of Columbia)
JC-DC-0003-0005 | JC-DC-0003-0006 | JC-DC-0003-0007
Defendant's Lawyers Carriere, Colin C. (District of Columbia)
JC-DC-0003-0003
Dorsch, Nancy R. (District of Columbia)
JC-DC-0003-0003
Ferren, John M. (District of Columbia)
JC-DC-0003-0005
Gross, Roberta L. (District of Columbia)
JC-DC-0003-0003
Grossman, Martin L. (District of Columbia)
JC-DC-0003-0003
Love, Richard Stuart (District of Columbia)
JC-DC-0003-0005
McKay, James C. (District of Columbia)
JC-DC-0003-0007
Prager, Lutz Alexander (District of Columbia)
JC-DC-0003-0006 | JC-DC-0003-0008
Reid, Herbert O. Sr. (District of Columbia)
JC-DC-0003-0006 | JC-DC-0003-0007
Reischel, Charles L. (District of Columbia)
JC-DC-0003-0006 | JC-DC-0003-0007 | JC-DC-0003-0008
Robinson, Jo Anne (District of Columbia)
JC-DC-0003-0008
Schwab, Edward E. (District of Columbia)
JC-DC-0003-0006
Smith, Walter A Jr. (District of Columbia)
JC-DC-0003-0005
Other Lawyers Rezneck, Daniel A. (District of Columbia)
JC-DC-0003-0005

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