John L., a juvenile whose last name is unknown, brought this civil rights action under 42 U.S.C. § 1983 through his next friend Andrew J. Shookhoff of the Vanderbilt Legal Clinic on November 7, 1988. Legal Services of South Central Tennessee also provided counsel for the plaintiff. The plaintiff ...
read more >
John L., a juvenile whose last name is unknown, brought this civil rights action under 42 U.S.C. § 1983 through his next friend Andrew J. Shookhoff of the Vanderbilt Legal Clinic on November 7, 1988. Legal Services of South Central Tennessee also provided counsel for the plaintiff. The plaintiff was 17 years old when he filed the suit alleging that he was being denied the right of access to the courts. At the time, plaintiff was incarcerated in the Taft Youth Center in Pikeville, Tennessee, a secure juvenile institution operated by the Tennessee Department of Youth Development (Department). Plaintiff was granted class certification on June 16, 1989, creating a class of plaintiffs that consists of those persons who are confined or will be confined in the four secure institutions operated by the Department. On February 28, 1990, the United States District Court for the Middle District of Tennessee (Magistrate Judge Kent Sandidge, III) granted summary judgment in favor of the juvenile plaintiff class. Judge Sandidge held that incarcerated juveniles have a right of access to the courts comparable to incarcerated adults and ordered the Department to submit a plan to remedy this constitutional violation. John L. v. Adams, 750 F.Supp. 288 (M.D.Tenn. 1990). The court's remedial order required the Department to establish contracts with private attorneys to provide part-time legal assistance to those held at juvenile institutions in Tennessee. The Department appealed, and the Sixth Circuit Court of Appeals affirmed the District Court's finding that incarcerated juveniles have a right of access to courts, including meaningful access to an attorney. John L. v. Adams, 969 F.2d 228 (6th Cir. 1992). The court relied on the Supreme Court's decision in Bounds v. Smith, 430 U.S. 817 (1977), which found an affirmative obligation upon states to provide all prisoners meaningful access to the courts. However, the court limited the juveniles' right of access in civil rights litigation under Section 1983 to only those actions related to incarceration. Also, the right of access did not require the Department to provide assistance to juvenile detainees for civil matters involving only state law. In accordance with the Sixth Circuit opinion, on October 30, 1992, Judge Sandidge modified the remedial order to remove the requirement that the state provide legal assistance in claims not related to detention and matters of state law. The case was dismissed on October 30, 1992, although subsequent litigation over attorneys' fees followed.
John L. v. Adams, 750 F.Supp. 288 (M.D.Tenn. Feb 28, 1990) (NO. 3:88-0924)
Affirmed in Part, Reversed in Part by
2 John L. v. Adams, 969 F.2d 228 (6th Cir.(Tenn.) Jul 17, 1992) (NO. 91-6241), rehearing deniedTom Madison - 01/16/2006