A.M. v. Luzerne County Juvenile Detention Center

Juvenile Law Center filed a federal civil rights suit in 2001 against the Luzerne County Juvenile Detention Center and several of its administrators and staff, alleging they violated the substantive due process rights of a 13-year-old boy with serious mental health problems by failing to protect him from harm while he was detained at the detention center. The suit alleged that the defendants failed to protect him from assaults by other residents in the facility and failed to provide him with proper medical and mental health care. The District Court in the Middle District of Pennsylvania ruled in favor of the defendants’ motion for summary judgment and dismissed the suit.

Juvenile Law Center appealed, and the Third Circuit Court of Appeals reversed, finding that there is potential liability for a county juvenile detention center. The Court found that the plaintiff raised serious issues and that a county can be liable for deficient hiring and staffing policies and practices; lack of an adequate training program for the detention center’s staff in critical areas such as de-escalating conflicts between youth and managing youth behavior generally; lack of established protocols to ensure youth safety; and lack of established policies to address the mental and physical health needs of its residents.