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Civil Rights Litigation Clearinghouse
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Case Name Morgan v. Sproat JI-MS-0003
Docket / Court 3:75-cv-00021-TSL-RHW ( S.D. Miss. )
State/Territory Mississippi
Case Type(s) Juvenile Institution
Attorney Organization ACLU Affiliates (any)
Southern Poverty Law Center
Case Summary
On February 4, 1975, juveniles at the Oakley Training School (OTS), a Mississippi state institution for delinquent boys, filed a class action lawsuit against the Department of Youth Services in the United States District Court for the Southern District of Mississippi pursuant to 42 U.S.C. § 1983 ... read more >
On February 4, 1975, juveniles at the Oakley Training School (OTS), a Mississippi state institution for delinquent boys, filed a class action lawsuit against the Department of Youth Services in the United States District Court for the Southern District of Mississippi pursuant to 42 U.S.C. § 1983. The plaintiffs, represented by Community Legal Services, alleged that the institution did not fulfill its intended purpose to rehabilitate youth and that the conditions at the institution violated their constitutional rights. The complaint alleged that the boys were punished by being placed in intensive treatment units where they were isolated for extended periods of time and that counseling programs, medical care, and legal services were all unconstitutionally deficient. They sought injunctive relief.

On April 3, 1975, Judge Walter Nixon certified the case as a class action of all present and future students confined at OTS, which at the time of filing consisted of 350 boys between the ages of 15 and 20. On October 8, 1975, the court appointed experts to the case, including two clinical psychologists.

On November 22, 1975, the court issued an order relating to disciplinary procedures. Under the order, defendants agreed to provide procedural safeguards, including prior notice and an impartial evidentiary hearing, to all OTS students accused of violating school rules and regulations. Defendants also promulgated a new code of rules, adopted by the court on November 26, 1976.

On April 18, 1977, Judge Nixon found that the policies in place at OTS violated plaintiffs' constitutional rights. Morgan v. Sproat, 432 F.Supp. 1130 (S.D. Miss. 1977). First, the court held the plaintiffs' due process rights were being violated, because the adjudication procedure used to commit juveniles to the state institution were developed with the intention that it be a therapeutic rather than punitive incarceration. As such, plaintiffs were being sent to a punitive state facility without due process for such punishment. Secondly, the court found that the conditions at the institution violated the Eighth Amendment's prohibition on cruel and unusual punishment. The court ordered that defendants were enjoined from placing juveniles in intensive treatment units except when they posed an immediate threat, and then for no more than twenty-four hours. The court further ordered that defendants develop educational, vocational, and recreational programming to meet the needs of the juveniles. The court enjoined defendants from isolating youth "whose psychological, emotional or intellectual status make isolation inappropriate." Defendants were also ordered to address overcrowding issues at the facility as well as increase access to dental and medical care. Finally, the court ordered that defendants forward requests by juveniles for legal representation to a legal services program. Attorney's fees were awarded.

The defendants continued to file reports of their progress and on July 3, 1981, Judge Nixon found that the no further reports were necessary as the defendants were found to be in compliance with the 1977 order.

On May 24, 2001, a new set of plaintiffs filed a motion to submit a supplemental complaint, but this motion was denied on April 1, 2004. In the meantime, however,the U.S. Department of Justice filed a report which revealed poor conditions at OTS. The report indicated that OTS had made little or no progress since 1977. After the DOJ released this report in 2003, the Southern Poverty Law Center joined the Mississippi Center for Justice to take over as class counsel in the litigation.

The DOJ filed its own lawsuit, U.S. v. Mississippi, 3:03-cv-01354-HTW-JCS, JI-MS-0004 in this Clearinghouse. Plaintiffs moved to consolidate the two cases; the U.S. did not oppose consolidation, but the Court refused to grant it. So this case continued on separately. No substantive activity appears in the docket after that, but new lawyers are added, and others withdrawn (as they changed jobs), and on June 26, 2015, the case was reassigned to Magistrate Judge Robert H. Walker. So it seems that the case is ongoing.

Emilee Baker - 05/16/2006
Abigail DeHart - 06/12/2017
Elena Malik - 02/01/2020

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Issues and Causes of Action
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Affected Gender
Constitutional Clause
Cruel and Unusual Punishment
Due Process
Content of Injunction
Crowding / caseload
Access to lawyers or judicial system
Disciplinary procedures
Recreation / Exercise
Totality of conditions
Medical/Mental Health
Dental care
Medical care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Causes of Action 42 U.S.C. § 1983
Defendant(s) Mississippi Department of Youth Services
Oakley Training School
Plaintiff Description All children who are now, or in the future will be, incarcerated in Oakley Training School, a juvenile training school in Mississippi, and all parents of these children.
Indexed Lawyer Organizations ACLU Affiliates (any)
Southern Poverty Law Center
Class action status sought Yes
Class action status outcome Granted
Filed Pro Se Unknown
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1975 - n/a
Filed 02/04/1975
Case Ongoing Yes
Case Listing JI-MS-0004 : U.S. v. Mississippi (S.D. Miss.)
Additional Resources
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  See this case at (May provide additional documents and, for active cases, real-time alerts)
  Morgan v. Sproat
Date: Aug. 1, 2003
(Southern Poverty Law Center)
[ Detail ] [ External Link ]

Court Docket(s)
S.D. Miss.
JI-MS-0003-9000.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
S.D. Miss.
JI-MS-0003-9001.pdf | Detail
Source: PACER [Public Access to Court Electronic Records]
General Documents
S.D. Miss.
Memorandum Opinion (432 F.Supp. 1130)
JI-MS-0003-0002.pdf | WESTLAW| LEXIS | Detail
Source: Google Scholar
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Judges Nixon, Walter Louis Jr. (S.D. Miss.) show/hide docs
Walker, Robert H. (S.D. Miss.) [Magistrate] show/hide docs
Plaintiff's Lawyers Atwood, Bear Hailey (Mississippi) show/hide docs
Bedi, Sheila A. (Mississippi) show/hide docs
JI-MS-0003-9000 | JI-MS-0003-9001
Bergmark, Martha (Mississippi) show/hide docs
Brownstein, Rhonda C. (Alabama) show/hide docs
JI-MS-0003-9000 | JI-MS-0003-9001
Carroll, Vanessa (Mississippi) show/hide docs
Cockrell, Corrie Wynette (Mississippi) show/hide docs
Graham, Grace Gabriel (Alabama) show/hide docs
Juneja, Poonam (California) show/hide docs
Levins, Kristen M. (Mississippi) show/hide docs
Lipow, Danielle Jeannine (Alabama) show/hide docs
JI-MS-0003-9000 | JI-MS-0003-9001
Miller, David B. (Mississippi) show/hide docs
Owens, Jody E. II (Mississippi) show/hide docs
Payne, Shirley (Mississippi) show/hide docs
Powell, Barry H. (Mississippi) show/hide docs
JI-MS-0003-0002 | JI-MS-0003-9000
Ramberg, Charles H. (Mississippi) show/hide docs
JI-MS-0003-0002 | JI-MS-0003-9000
Defendant's Lawyers Googe, P. Roger Jr. (Mississippi) show/hide docs
JI-MS-0003-0002 | JI-MS-0003-9000

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