Filed Date: Jan. 1, 1990
Closed Date: 1991
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On 10/24/1986, a group of criminal defense attorneys and indigent criminal defendants filed a 42 U.S.C. § 1983 class action lawsuit against Georgia state officials (including the governor and all state court judges responsible for appointing attorneys to indigent criminal defendants) in the U.S. District Court for the Northern District of Georgia. The plaintiffs claimed that a number of inadequacies in Georgia's indigent criminal defense system (including inadequate resources, delays in the appointment of counsel, pressure on attorneys to hurry their clients' case to trial or to enter a guilty plea, and inadequate supervision) deprived indigent criminal defendants of their rights to counsel, due process, and equal protection. Plaintiffs, represented by the ACLU, the Georgia Law Center for the Homeless, and private counsel, sought injunctive relief to remedy the alleged deficiencies.
On June 24, 1987 and December 31, 1988, the District Court (Judge Harold L. Murphy) granted Defendants' motion to dismiss on two alternate grounds. First, the District Court reasoned that, while individual state officials had been the nominal defendants, the suit was, in essence, brought against the State of Georgia and was therefore barred by the Eleventh Amendment. Second, the District Court held that, independent of the Eleventh Amendment rationale, the suit ought to be dismissed because Plaintiffs' complaint failed to state a claim for which relief could be granted. Plaintiffs appealed to the U.S. Court of Appeals for the Eleventh Circuit.
On November 23, 1988, a panel of the Eleventh Circuit (Judge Robert Smith Vance) reversed, rejecting both grounds for the District Court's dismissal. Luckey v. Harris, 860 F.2d 1012 (11th Cir. 1988). The Court first held that the suit was not barred by Eleventh Amendment immunity because, under the Ex Parte Young exception to the Eleventh Amendment, a suit seeking prospective relief against state officials is not deemed to be a suit against the state. The Eleventh Circuit also rejected the second ground for the District Court's dismissal, holding that Plaintiffs' complaint stated a claim upon which relief could be granted despite the fact that it did not allege the "future inevitability of ineffective assistance." The Court thereby reversed the dismissal and remanded to the District Court.
The defendants were unsuccessful in their attempts to have the Eleventh Circuit panel's decision overturned. On December 29, 1989, the Eleventh Circuit, in a per curiam decision, denied Defendants' petition for rehearing or rehearing en banc, Luckey v. Harris, 896 F.2d 479 (11th Cir. 1989), and, on May 29, 1990, the U.S. Supreme Court denied Defendants' petition for a writ of certiorari, Luckey v. Harris, 495 U.S. 957 (1989).
Upon remand to the District Court, the defendants filed a renewed motion to dismiss the case on the basis of the abstention doctrine as set forth in Younger v. Harris, 401 U.S. 37 (1971). On July 10, 1990 the District Court denied the renewed motion to dismiss, holding that it was bound by the law of the case. The District Court reasoned that, while the Eleventh Circuit had not explicitly ruled on the abstention issue, it had sent the clear message that the case should be heard. The District Court nevertheless certified the issue for immediate appeal. The Eleventh Circuit (Judge Stanley F. Birch, Jr.) agreed to hear the case, Luckey v. Miller, 918 F.2d 888 (11th Cir. 1991), and, on April 23, 1991, the Eleventh Circuit (Judge Joel Fredrick Dubina) reversed on the law of the case issue, Luckey v. Miller, 929 F.2d 618 (11th Cir. 1991). The case was again remanded.
On remand, the District Court (Judge Murphy) considered Defendants' abstention argument and, on that ground, dismissed the case on December 16, 1991. The dismissal was affirmed by the Eleventh Circuit on November 4, 1992. Luckey v. Miller, 976 F.2d 673 (11th Cir. 1992) (per curiam).
According to the PACER docket, no further appeals were taken and the case was closed.
Summary Authors
Krista Swip (7/12/2007)
Birch, Stanley F. Jr. (Georgia)
Cox, Emmett Ripley (Alabama)
Aphrin, Derek (Georgia)
Bradley, Neil T. (Georgia)
Cromartie, John L. Jr. (Georgia)
Birch, Stanley F. Jr. (Georgia)
Cox, Emmett Ripley (Alabama)
Dubina, Joel Fredrick (Alabama)
Dyer, David William (Georgia)
Edmondson, James Larry (Georgia)
Fay, Peter Thorp (Florida)
Hatchett, Joseph Woodrow (Florida)
Kravitch, Phyllis A. (Georgia)
Murphy, Harold Lloyd (Georgia)
Scott, Thomas Emerson Jr. (Florida)
Tjoflat, Gerald Bard (Florida)
Vance, Robert Smith (Alabama)
Last updated March 29, 2024, 3:09 a.m.
State / Territory: Georgia
Case Type(s):
Key Dates
Filing Date: Jan. 1, 1990
Closing Date: 1991
Case Ongoing: No
Plaintiffs
Plaintiff Description:
All indigent persons presently charged or who will be charged in the future with criminal offenses in the courts of Georgia and all attorneys who represent or will represent indigent defendants in the Georgia courts
Attorney Organizations:
NDRN/Protection & Advocacy Organizations
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: Yes
Class Action Outcome: Granted
Defendants
Case Details
Causes of Action:
Constitutional Clause(s):
Available Documents:
Outcome
Prevailing Party: Defendant
Nature of Relief:
Source of Relief:
Issues
Reproductive rights:
General: