## Facts

- Juveniles confined at Rhode Island’s Boys’ Training School (BTS) brought a § 1983 class action against state officials responsible for BTS operations and transfer decisions.
- BTS housed youths committed for varied reasons, including delinquency, status offenses, and abuse/neglect; “problem” youths were often moved from cottages to more restrictive settings.
- Challenged placements included: Annex B (a former women’s prison cellblock), solitary cells in an adult medium–minimum facility, the adult ACI maximum-security building (and an adult medium-security wing), and the Youth Correctional Center (Annex C).
- In the challenged buildings, youths received little to no education, had minimal exercise or outdoor time, and endured dark, cold, bare cells.
- Evidence showed deprivation of basic hygiene items and medications and, at times, extended periods without food.
- Mental-health resources were effectively unavailable; BTS had no psychiatrists or psychologists on staff, including for youths held in isolation.
- Solitary confinement could last up to 15 days, often without meaningful review or professional oversight.
- Transfers from BTS to adult facilities or highly restrictive placements were commonly imposed without advance notice, a hearing, or judicial review.
- Plaintiffs sought preliminary injunctive and declaratory relief to stop confinement in specified adult and annex facilities, limit isolation absent psychiatric certification, and constrain transfer practices.

## Issues

1. Whether the cumulative conditions imposed on juveniles in Annex B and adult-institution units constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments.
2. Whether transferring juveniles from BTS to adult correctional facilities or extended isolation without notice and an opportunity to be heard violated Fourteenth Amendment due process.
3. Whether imposing substantially harsher treatment on certain BTS youths, including adult maximum-security confinement, violated equal protection.
4. Whether the rehabilitative purpose of juvenile commitment constrained the state from using punitive conditions that eliminated education and therapeutic services.

## Decision

- The court granted injunctive relief for the plaintiff class.
- It held that conditions in Annex B and the adult-institution placements used for BTS youths were unconstitutional as applied to juveniles.
- It held that administrative transfers to substantially more restrictive, adult penal settings, and extended isolation without adequate procedural safeguards, violated due process.
- It enjoined confinement of BTS juveniles in the ACI maximum-security building, in solitary cells in the medium–minimum security building, and in Annex B as then operated.
- It restricted use of Annex C and isolation to circumstances justified by clinical or comparable professional oversight, with time limits and minimum standards for basic care and programming.

## Legal Principles

- Juveniles in state custody retain constitutional protections; conditions of confinement are reviewable under the Eighth and Fourteenth Amendments.
- Conditions may be unconstitutional based on their cumulative impact, including denial of education, exercise, hygiene, medical care, adequate food, and the use of prolonged isolation.
- When a transfer or placement substantially increases the severity and stigma of confinement (including movement to adult maximum-security settings), due process requires, at minimum, notice and an opportunity to be heard before an impartial decision-maker.
- The state may not justify adult penal conditions for juveniles by labeling the placement “discipline” where the regime is inconsistent with basic decency and the asserted rehabilitative purpose of juvenile commitment.
- Federal injunctive relief is appropriate where ongoing unconstitutional conditions and transfer practices require enforceable minimum standards and limits.

## Conclusion

The court concluded that Rhode Island’s use of adult maximum-security placements, harsh annex confinement, and prolonged isolation for BTS juveniles imposed unconstitutional conditions and unlawfully increased confinement severity without due process; it issued injunctive orders barring specified placements and requiring procedural and minimum-conditions protections for juveniles.


Inmates of the Boys’ Training Sch. v. Affleck, 346 F. Supp. 1354 (D.R.I. 1972)