Brandon E. v. The Honorable Abram F. Reynolds
Juvenile Law Center challenged the constitutionality of a Pennsylvania statute, Act 53, which allows parents to petition the juvenile court to obtain involuntary, inpatient treatment for minors afflicted with a drug or alcohol dependency. The named plaintiffs were three minors who were the subject of such proceedings. The defendants were county judges responsible for presiding over Act 53 cases, who were sued only in their official capacity.
The district court dismissed the action on the ground that the judges, as "neutral adjudicators," are not the proper parties to defend the constitutionality of this statute. The Third Circuit Court of Appeals affirmed this dismissal on appeal.