University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name United States v. City of Meridian JI-MS-0010
Docket / Court 3:13-cv-00978-HTW-LRA ( S.D. Miss. )
Additional Docket(s) 4:12-cv-168  [ 12-168 ]
State/Territory Mississippi
Case Type(s) Juvenile Institution
Policing
Attorney Organization U.S. Dept. of Justice Civil Rights Division
Case Summary
On December 1, 2011, the Department of Justice Civil Rights Divisions launched an investigation of the Meridian Police Department and the Lauderdale County Youth Court pursuant to 42 U.S.C. § 14141 and 42 U.S.C. § 2000d. The DOJ expanded their investigation to include the Mississippi Division of ... read more >
On December 1, 2011, the Department of Justice Civil Rights Divisions launched an investigation of the Meridian Police Department and the Lauderdale County Youth Court pursuant to 42 U.S.C. § 14141 and 42 U.S.C. § 2000d. The DOJ expanded their investigation to include the Mississippi Division of Youth Services on June 29, 2012. On August 10, 2012, the DOJ published their findings that the agencies in question had violated the constitutional rights of the children under the Fourth, Fifth, and Fourteenth Amendments. The DOJ provided the agencies an opportunity to cure the offending behavior but no negotiations occurred.

On October 24, 2012, the United States filed a lawsuit against the agencies in the Southern District of Mississippi under 42 U.S.C. §14141. The government alleged that the defendants in the investigation collectively helped to operate a "school-to-prison pipeline." The government sought declaratory relief, an order permanently enjoying defendants from the alleged unlawful practices, an order requiring defendants to effectuate corrected polices, and other equitable relief.

This was the first lawsuit brought under a "school-to-prison pipeline" legal theory. Under this theory, the government claimed that the defendants systematically incarcerated children in Meridian for allegedly committing minor offenses and punished children disproportionately without due process. The government alleged that the Meridian Police Department would automatically arrest students referred by the Meridian Public School District without assessing the nature of the referral and without probable cause. Students were not provided adequate information regarding their rights. Students were then commonly held for more than 48 hours while they awaited youth court "detention hearings" that did not meet the Due Process requirement of the Constitution. These acts violated the constitutional rights of the children under the Fourth, Fifth, and Fourteenth Amendments.

On December 7, 2012, defendants filed a motion to dismiss based on Younger abstention. On September 4, 2013, United States District Judge Henry T. Wingate denied the motion. Judge Wingate noted that the government's interest in eliminating a pattern or practice of constitutional violations was not necessarily identical to the interests of individual children facing delinquency proceedings in state court. Moreover, the government's interest was not so "intertwined" with such individuals so as to justify barring prospective relief to a person not a party to the challenged state actions. The government may have interests that transcends that of private state defendants.

On December 26, 2013, the case was transferred to the Northern Division and assigned a new case number.

During 2014 and early 2015, the parties engaged in discovery and negotiated out of court. The negotiations culminated in a March 4, 2015 telephone conference in which the parties, except for the defendant judges and Lauderdale County, announced that they had reached a settlement. After reviewing the settlements, Judge Wingate issued two opinions on September 18, 2015. The first granted a motion for settlement between the United States and the City of Meridian. The second granted a motion for settlement between the United States and the State of Mississippi, the Mississippi Department of Human Services, and the Mississippi Division of Youth Services. See DOJ 15-768 (D.O.J.), 2015 WL 3809399. Defendant Lauderdale County and the two individual defendants, judges of the Lauderdale County Youth Court, were not parties to either of the settlements.

The first settlement focused on improving the conduct of the Meridian Police Department (MPD) in Meridian's public schools. It limited MPD's authority to arrest juveniles at school, required additional documentation of school-based arrests, and instituted reforms related to MPD training, complaint procedures, data collection, and coordination with the Meridian Public School District Police Department. The parties agreed that a Police Independent Auditor would supervise compliance and that the agreement would terminate after 12 consecutive months of "substantial compliance" by the City of Meridian. On March 18, 2016, the parties agreed on who should serve as Police Independent Auditor after a budget dispute, and Judge Wingate approved their choice on March 25, 2016.

The second settlement focused on improving the conduct of the Mississippi Division of Youth Services (DYS), which managed probation for youths. It required DYS to inform youths on probation of the probation process and their rights within it, limited the ability of DYS to incarcerate youths for probation violations, increased procedural protections for youths on probation, and initiated training and community involvement programs. The parties agreed that a Probation Services Independent Auditor would supervise compliance and that the agreement would terminate after 12 consecutive months of "substantial compliance" by DYS. On January 5, 2016, the parties notified the court that they had agreed on the Probation Services Independent Auditor.

Meanwhile, the case against defendant Youth Court judges continued. The judges had moved to dismiss the claims against them on November 25, 2014. The court finally granted their motions on September 30, 2017. The judges argued that they were protected by judicial immunity and the Rooker-Feldman doctrine, which prevents parties that lost in state courts from re-litigating their claims in federal court. Judge Wingate found that the Rooker-Feldman doctrine did not apply because the United States did not seek to challenge a state court judgment against it. However, Judge Wingate granted defendants' motion under the theory of judicial immunity, which bars most claims against judges acting within their official capacities and jurisdiction, and declined the United States' invitation to apply 42 U.S.C. § 14141 to judges. The suit against Lauderdale County was dismissed as well, because it was "inextricably intertwined" with that against its judges. 2017 WL 6810621. On November 28, 2017, the United States appealed to the United States Court of Appeals for the Fifth Circuit. The appeal is pending (Docket No. 17-60805).

Throughout 2016 and 2017, the independent auditors monitored compliance with the settlement agreements and submitted a number of status updates. On January 16, 2018, the Police Independent Auditor filed a final report which stated that the City of Meridian and the Meridian Police Department were in substantial compliance with all of the settlement's requirements. The parties agreed to transfer the responsibility for monitoring compliance from the independent monitor to the United States. The United States submitted its first compliance report on September 12, 2018, which found that the City of Meridian and its police remained in substantial compliance.

In contrast, the Probation Services Independent Auditor's Fifth Report, filed on April 2, 2018, identified several areas in which the state was not in substantial compliance with the settlement agreement. While recognizing that the state had made progress, the Auditor found that the State had failed to fully meet its obligation to review its policies and procedures, draft new policies and procedures when necessary, and improve training as required by the agreement. The Auditor also noted that defendant Youth Court judges refused access to Youth Court files, possibly due to the continuing litigation against them. Both settlement agreements continue to be monitored.

Richard Jolly - 11/18/2014
Timothy Leake - 10/18/2018


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Issues and Causes of Action
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Issues
Constitutional Clause
Due Process
Defendant-type
Jurisdiction-wide
Law-enforcement
General
Access to lawyers or judicial system
Disparate Treatment
Juveniles
Plaintiff Type
U.S. Dept of Justice plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 14141
Title VI, Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.
Defendant(s) City of Meridian
County of Lauderdale
Lauderdale County Youth Center
Mississippi Department of Human Services
Mississippi Division of Youth Services
Named Judges
Plaintiff Description The Department of Justice Civil Rights Division, on behalf of youths arrested, tried, and detained in Lauderdale County, Mississippi.
Indexed Lawyer Organizations U.S. Dept. of Justice Civil Rights Division
Class action status sought No
Class action status granted No
Filed Pro Se No
Prevailing Party Mixed
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 2015 - n/a
Filing Year 2012
Case Ongoing Yes
Additional Resources
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  Data examining the Department of Justice's civil rights investigations of local and state police departments
Marshall Project
Date: Jan. 17, 2017
By: Tom Meagher (Marshall Project)
[ Detail ] [ External Link ]

  The Civil Rights Division’s Pattern and Practice Police Reform Work: 1994-Present
https://www.justice.gov/
Date: Jan. 4, 2017
By: U.S. Department of Justice
[ Detail ] [ External Link ]

  An Interactive Guide to the Civil Rights Division’s Police Reforms
https://www.justice.gov/
Date: Jan. 4, 2017
By: U.S. Department of Justice Civil Rights Division (U.S. Department of Justice)
[ Detail ] [ External Link ]

  What Happens When Police Are Forced to Reform?
Date: Nov. 13, 2015
By: Kimbriell Kelly, Sarah Childress and Steven Rich (Frontline/Post)
Citation: Washington Post (Nov. 13, 2015)
[ Detail ] [ External Link ]

  Federal Enforcement of Police Reform
Date: 2014
By: Stephen Rushin (University of Illinois College of Law, University of California, Berkeley - Jurisprudence and Social Policy Program Faculty)
Citation: 82 Fordham Law Review 3189 (2014)
[ Detail ] [ External Link ]

Docket(s)
4:12-cv-168 (S.D. Miss.)
JI-MS-0010-9000.pdf | Detail
Date: 09/12/2018
Source: PACER [Public Access to Court Electronic Records]
General Documents
Findings Letter (2012)
JI-MS-0010-0001.pdf | Detail
Date: 08/10/2012
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Justice Department Releases Investigative Findings Showing Constitutional Rights of Children in Mississippi Being Violated
JI-MS-0010-0005.pdf | External Link | Detail
Date: 08/10/2012
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Justice Department Files Lawsuit in Mississippi to Protect the Constitutional Rights of Children
JI-MS-0010-0007.pdf | External Link | Detail
Date: 10/24/2012
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Complaint [ECF# 1]
JI-MS-0010-0002.pdf | Detail
Date: 10/24/2012
Source: PACER [Public Access to Court Electronic Records]
Order Denying Defendants' Motion to Dismiss Based on Younger Abstention [ECF# 20] (S.D. Miss.)
JI-MS-0010-0003.pdf | Detail
Date: 09/04/2013
Source: PACER [Public Access to Court Electronic Records]
Justice Department Reaches Settlement Agreements to Address Unconstitutional Youth Arrest and Probation Practices in Meridian, Mississippi
JI-MS-0010-0006.pdf | External Link | Detail
Date: 06/19/2015
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Joint Motion for Entry of Settlement Agreement [ECF# 77]
JI-MS-0010-0008.pdf | External Link | Detail
Date: 06/19/2015
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Memorandum in Support of Joint Motion for Entry of Settlement Agreement [ECF# 78]
JI-MS-0010-0009.pdf | External Link | Detail
Date: 06/19/2015
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Joint Motion for Entry of Settlement Agreement [ECF# 79]
JI-MS-0010-0015.pdf | External Link | Detail
Date: 06/19/2015
Source: PACER [Public Access to Court Electronic Records]
Memorandum in Support of Joint Motion for Entry of Settlement Agreement [ECF# 81]
JI-MS-0010-0016.pdf | External Link | Detail
Date: 06/19/2015
Source: PACER [Public Access to Court Electronic Records]
Settlement Agreement [ECF# 83] (S.D. Miss.)
JI-MS-0010-0010.pdf | External Link | Detail
Date: 09/18/2015
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
State Settlement Agreement [ECF# 84]
JI-MS-0010-0004.pdf | Detail
Date: 09/18/2015
Source: PACER [Public Access to Court Electronic Records]
First Report of the Probation Services Independent Auditor  [ECF# 96-1]
JI-MS-0010-0011.pdf | External Link | Detail
Date: 03/07/2016
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Second Report of the Probation Services Independent Auditor
JI-MS-0010-0012.pdf | External Link | Detail
Date: 09/05/2016
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Interim Compliance Report [Settlement Agreement]
JI-MS-0010-0013.pdf | External Link | Detail
Date: 09/26/2016
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Third Report of the Probation Services Independent  Auditor  [ECF# 103-1]
JI-MS-0010-0014.pdf | External Link | Detail
Date: 02/28/2017
Source: U.S. Department of Justice, Civil Rights Division, Special Litigation Section
Compliance Report
JI-MS-0010-0017.pdf | External Link | Detail
Date: 06/13/2017
Memorandum Opinion and Order [ECF# 116] (2017 WL 6810621) (S.D. Miss.)
JI-MS-0010-0019.pdf | WESTLAW | Detail
Date: 09/30/2017
Source: PACER [Public Access to Court Electronic Records]
Fourth Report of the Probation Services Independent Auditor [ECF# 118-1]
JI-MS-0010-0018.pdf | External Link | Detail
Date: 10/14/2017
Source: PACER [Public Access to Court Electronic Records]
Fifth Report of the Probation Services Independent Auditor [ECF# 125]
JI-MS-0010-0020.pdf | Detail
Date: 04/02/2018
Source: PACER [Public Access to Court Electronic Records]
Re: United States' First Assessment of the City of City of Meridian's Compliance with the Settlement Agreement [ECF# 126-1]
JI-MS-0010-0021.pdf | Detail
Date: 09/12/2018
Source: PACER [Public Access to Court Electronic Records]
Judges Anderson, Linda Randle (S.D. Miss.) [Magistrate]
JI-MS-0010-9000
Wingate, Henry Travillion (S.D. Miss.)
JI-MS-0010-0003 | JI-MS-0010-0004 | JI-MS-0010-0010 | JI-MS-0010-0019 | JI-MS-0010-9000
Monitors/Masters Monroe, Rodney (North Carolina)
JI-MS-0010-0013 | JI-MS-0010-0017
Shoenberg, Dana (District of Columbia)
JI-MS-0010-0011 | JI-MS-0010-0012 | JI-MS-0010-0014 | JI-MS-0010-0018 | JI-MS-0010-0020
Plaintiff's Lawyers Austin, Roy L. (District of Columbia)
JI-MS-0010-0002 | JI-MS-0010-9000
Cuncannan, Jacqueline (District of Columbia)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-9000
Davis, Gregory K. (Mississippi)
JI-MS-0010-0002 | JI-MS-0010-0004 | JI-MS-0010-0005 | JI-MS-0010-0006 | JI-MS-0010-0007 | JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-0016 | JI-MS-0010-9000
Goemann, Richard C. (District of Columbia)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-9000
Gupta, Vanita (District of Columbia)
JI-MS-0010-0006 | JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-0016
Jackson, Shelley (District of Columbia)
JI-MS-0010-0002 | JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-0016 | JI-MS-0010-9000
Jernigan, Alfred B. Jr. (Mississippi)
JI-MS-0010-0002 | JI-MS-0010-9000
Jones, Michelle A. (District of Columbia)
JI-MS-0010-0002 | JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-9000
Kappelhoff, Mark (District of Columbia)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-0016
Ogletree, Rashida J (District of Columbia)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-0016 | JI-MS-0010-9000
Paige, Mitzi Dease (Mississippi)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-0016 | JI-MS-0010-9000
Perez, Thomas E. (District of Columbia)
JI-MS-0010-0001 | JI-MS-0010-0002 | JI-MS-0010-0005 | JI-MS-0010-0007 | JI-MS-0010-9000
Porter, Forestine Nicole (District of Columbia)
JI-MS-0010-0021 | JI-MS-0010-9000
Preston, Judy C. (District of Columbia)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-0010 | JI-MS-0010-0015 | JI-MS-0010-0016
Rifkin, Lori Ellen (District of Columbia)
JI-MS-0010-0002 | JI-MS-0010-9000
Smith, Jonathan Mark (District of Columbia)
JI-MS-0010-0002 | JI-MS-0010-9000
Defendant's Lawyers Bailey, Robert Thomas (Mississippi)
JI-MS-0010-9000
Darsey, Reed C. (Mississippi)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-9000
Goggans, Michael D. (Mississippi)
JI-MS-0010-9000
Miracle, Douglas T. (Mississippi)
JI-MS-0010-0004 | JI-MS-0010-0015 | JI-MS-0010-0016 | JI-MS-0010-9000
Palmer, Henry (Mississippi)
JI-MS-0010-9000
Pizzetta, Harold Edward III (Mississippi)
JI-MS-0010-9000
Thaggard, Lee (Mississippi)
JI-MS-0010-9000
Walton, Ronnie Leigh (Mississippi)
JI-MS-0010-0008 | JI-MS-0010-0009 | JI-MS-0010-9000
Wright, Charles W. Jr. (Mississippi)
JI-MS-0010-9000

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