## Facts

- A certified class of juveniles were detained as pretrial detainees in the Columbia County Correctional Facility (CCCF), an adult jail in St. Helens, Oregon; CCCF did not house convicted juvenile offenders.
- Many detained juveniles were status offenders (e.g., runaways) held for non-criminal conduct applicable only to minors.
- CCCF housed adults and juveniles, at times placing juveniles within sight and sound of adult inmates.
- CCCF’s operating philosophy was openly punitive, intending to make jail a punishment.
- Juveniles slept on urethane-covered mattresses or concrete floors and lacked basic privacy for toileting and showering, including exposure to members of the opposite sex.
- The jail was understaffed, staff lacked special training for juveniles, and the facility had no juvenile programs or written policies, resulting in arbitrary decision-making by jailers.
- Juveniles experienced restrictions and deprivations including limited phone access; lack of underwear; lack of writing, recreation materials, natural light, and exercise; and inconsistent access to family visits, attorneys, nutritious food, medical care, and protection from harm.
- Some juveniles, including younger children, were placed in isolation cells under severe conditions, including unsanitary arrangements for bodily needs and no consistent governing policy.
- A special grand jury previously identified numerous deficiencies and recommended that juveniles not be kept in CCCF until conditions were remedied.
- Plaintiffs brought a § 1983 class action for declaratory and injunctive relief, alleging the conditions constituted unconstitutional punishment under the Fourteenth Amendment.

## Issues

1. Whether the conditions and restrictions imposed on juvenile pretrial detainees in an adult jail constituted “punishment” in violation of the Fourteenth Amendment Due Process Clause.
2. Whether confining juvenile status offenders in an adult jail constituted unconstitutional punishment, and whether any conditions could make such confinement constitutional.

## Decision

- The court held that the conditions at CCCF amounted to unconstitutional punishment of juvenile pretrial detainees in violation of Fourteenth Amendment due process.
- The court held that confining status offenders in an adult jail constituted unconstitutional punishment.
- The court granted declaratory relief and determined plaintiffs were entitled to a permanent injunction barring continued juvenile confinement at CCCF under the existing conditions.
- The court awarded reasonable attorneys’ fees and directed submission of a proposed judgment.

## Legal Principles

- Under the Fourteenth Amendment, pretrial detainees may be detained for legitimate governmental objectives (such as ensuring court appearance or safety) but may not be subjected to conditions that amount to punishment.
- Conditions are unconstitutional punishment when they reflect punitive intent or have a punitive effect and are not reasonably related to legitimate, nonpunitive governmental objectives.
- Housing juveniles—especially status offenders—in an adult jail can be inherently punitive, including by treating them as criminals and exposing them to adult-jail conditions.
- Severe deprivations of basic needs, lack of minimally adequate services, arbitrary administration, and use of harsh isolation without adequate justification support a finding that confinement conditions constitute punishment.

## Conclusion

The court concluded that CCCF’s adult-jail confinement of juvenile pretrial detainees—particularly status offenders—was punitive in intent and effect and not justified by legitimate governmental objectives, violating due process; it therefore ordered permanent injunctive and declaratory relief and awarded attorneys’ fees.


D.B. v. Tewksbury, 545 F. Supp. 896 (D. Or. 1982)