## Facts

- A class of juveniles alleged or adjudicated as “Persons In Need of Supervision” (PINS) under New York law were temporarily detained in New York City maximum-security juvenile centers: Spofford (boys) and Manida and Zerega (girls).
- PINS status covered noncriminal conduct such as truancy or being incorrigible or habitually disobedient beyond parental control.
- Plaintiffs were held in secure, prison-like settings, often alongside juvenile delinquents charged with or adjudicated for delinquent (criminal-type) acts.
- Plaintiffs brought a federal civil rights action seeking declaratory and injunctive relief, alleging violations of due process and equal protection and, given the conditions, cruel and unusual punishment.
- The state statute authorized PINS detention before a court return date if there was a substantial probability of nonappearance or a serious risk of criminal-type conduct before the return date.
- After an evidentiary hearing (consolidated with the preliminary injunction hearing), the court evaluated conditions and programming, including whether the centers provided rehabilitative or therapeutic services.

## Issues

1. Whether long-term secure confinement of PINS without constitutionally adequate rehabilitative treatment violates due process.
2. Whether conditions at the Manida center were so unsafe and deteriorated as to constitute cruel and unusual punishment.
3. Whether housing PINS together with juvenile delinquents in maximum-security centers denies equal protection.

## Decision

- The court held that conditions at the Manida center were unconstitutional and amounted to cruel and unusual punishment.
- The court held that, for children held for extended periods, the centers’ programs did not provide constitutionally adequate treatment; long-term secure confinement without such treatment violated due process.
- The court rejected the equal protection challenge to joint custody of PINS and juvenile delinquents, concluding that placement decisions were based on individualized assessments and professional judgment rather than the formal PINS/delinquent label.
- The court contemplated injunctive relief requiring corrective measures consistent with its findings, including that Manida could not continue operating under unconstitutional conditions and that long-term detainees required adequate treatment.

## Legal Principles

- When the state confines noncriminal juveniles on a rehabilitative rationale, due process requires minimally adequate, meaningful treatment for those held for extended periods; confinement without such treatment is unconstitutional.
- Juvenile detention conditions must meet basic standards of decency; severely dilapidated, unsafe, and unhealthy conditions can constitute cruel and unusual punishment.
- Equal protection is not violated merely because non-delinquent and delinquent juveniles share secure facilities if classification and placement are grounded in individualized risk and treatment needs supported by professional judgment.

## Conclusion

The court found constitutional violations in (1) the Manida facility’s physical conditions and (2) the lack of adequate treatment for long-term PINS detainees, but it declined to hold that joint housing of PINS with juvenile delinquents is unconstitutional absent proof that placements are irrational or label-driven rather than individualized.


Martarella v. Kelley, 349 F. Supp. 575 (S.D.N.Y. 1972)