On October 10, 1975, October 24, 1975, and December 12, 1975, juveniles confined in an industrial school and juvenile camp in Puerto Rico filed three, later consolidated, lawsuits under 42 U.S.C. § 1983 against Mayaguez Industrial School and Maricao Juvenile Camp in the U.S. District Court for the District of Puerto Rico. The plaintiffs, represented by P.R. Legal Services and the National Juvenile Law Center, asked the court for declaratory and injunctive relief, alleging that juveniles confined in the Mayaguez Industrial School and the Maricao Juvenile Camp, were being denied their constitutional and civil rights (a) to due process of law prior to denial of liberty, (b) to be free from cruel and unusual punishment, (c) to be free form involuntary servitude, (d) to equal protection of the laws, and (d) to rehabilitation and treatment services. Specifically, the plaintiffs challenged: (1) the utilization of extensive seclusion in solitary confinement without basic necessities and treatment services; (2) prolonged disciplinary confinement imposed without due process; (3) the lack of individualized, comprehensive rehabilitation plans; (4) inadequate education and rehabilitation; (5) inadequate medical care, including lack of psychiatric and psychological services; (6) unsanitary conditions; (7) the lack of opportunities for physical exercise and recreation; and (8) inadequately qualified and trained staff.
On August 10, 1976, the District (Judge Juan R. Torruella) certified the consolidated actions as class actions composed of all present and future juveniles committed to the Industrial School and Juvenile Camp.
On November 29, 1976, the United States sought to intervene alleging further violation of plaintiffs' rights under the Fourth, Fifth, Eighth, Ninth, Thirteenth and Fourteenth Amendments. Specifically, the complaint in intervention contended: (1) juveniles with intellectual disabilities, emotional disturbance and other handicaps were inappropriately placed in institutions without appropriate treatment services; (2) placements were made without consideration of less restrictive alternative community-based placements; (3) juveniles were denied treatment and rehabilitative care due to inadequate staff, facilities and health and safety standards; (4) juveniles were subjected to extreme and unnecessary disciplinary measures, including prolonged solitary confinement and corporal punishment; (5) juveniles were forced to undergo excessive and/or non-therapeutic sedation of tranquilizing drugs; (6) juveniles were forced to perform non-therapeutic, institution-maintaining labor without financial compensation; and (7) juveniles were deprived of adequate and appropriate education, training and treatment services.
On December 3, 1979, a sixteen day trial on the merits began at the District Court. During the trial, the defendants filed a motion challenging the United States' authority to intervene. While Judge Torruella initially granted the motion on June 5, 1980, the Civil Rights of Institutionalized Persons Act (CRIPA) was subsequently passed on May 23, 1980, and Judge Torruella reviewed his June 5 decision.
On September 11, 1980, the District Court (Judge Torruella) conditionally affirmed his initial order, finding that absent statutory authority, the United States lacked standing to intervene, but that CRIPA could allow for intervention where the "action truly involves matters of general public importance." Santana v. United States, 88 F.R.D. 549 (D.P.R. 1980).
On January 27, 1981, the District Court (Judge Torruella) granted the United States' motion to intervene pursuant to the provisions of CRIPA. Santana v. Collazo, 89 F.R.D. 369 (D.P.R. 1981).
On February 15, 1982, the District Court (Judge Torruella) rejected the juveniles proposed right to treatment, but agreed that conditions were reviewable under the Eighth and Fourteenth Amendments, concluding that "the truth lies somewhere between Plaintiffs' contentions to the effect that conditions at the juvenile facilities resemble the Black Hole of Calcutta and Defendants' version that they approximate a Hollywood version of Father Flanagan's Boys' Town." Santana v. Collazo, 533 F. Supp. 966 (D.P.R. 1982). Judge Torruella held that (a) plaintiffs did not have a constitutional right to treatment, (b) the conditions of confinement of juveniles at Mayaguez and Maricao were subject to review pursuant to the Cruel and Unusual Punishment Clause of the Eighth Amendment and the Due Process Clause of the Fourteenth Amendment, and (c) all conditions not expressly enjoined did not violate the plaintiffs' constitutional rights.
Judge Torruella: (1) banned juveniles from being committed to the intensive care or isolation unit solely based on illness; (2) banned physical or corporal abuse; (3) ordered the defendants to post written disciplinary rules; (4) required due process hearings before juveniles could be confined; and (5) banned detention of pre-trial juvenile detainees in the intensive care or isolation units.
On August 8, 1983, the First Circuit Court of Appeals (Judge Frank M. Coffin) affirmed in part and vacated and remanded in part. Santana v. Collazo, 714 F.2d 1172 (1st Cir. 1983). Judge Coffin held that (a) there was no constitutional right to rehabilitative treatment for juveniles within the custody of Puerto Rico, and (b) remand was necessary to determine whether the isolation employed by Puerto Rice related to any legitimate government objectives.
On May 14, 1985, the United States Supreme Court denied certiorari. Santana v. Collazo, 466 U.S. 974 (1984).
Sometime before 1986, the District Court (Judge Torruella) approved isolation as used at one facility as constitutional. The plaintiffs appealed.
On June 11, 1986, the First Circuit (Judge Coffin) vacated and remanded, holding that further development of the record was necessary in order for the Court to determine whether isolation as used by the juvenile detention facility was constitutional. Santana v. Collazo, 493 F.2d 41 (1st Cir. 1986).
Because we have no further opinions, we have no more information on this file.Josh Altman - 05/23/2006