## Facts

- Juveniles adjudicated delinquent in Texas brought a class action on behalf of all youths involuntarily committed to the Texas Youth Council (TYC) and assigned to one of six state training schools.
- Defendants included the TYC executive director, TYC board members, and institutional staff responsible for supervision and discipline.
- The litigation shifted to conditions of confinement and treatment within TYC facilities, including maximum-security confinement at Mountain View, where some youths were held for status-type misconduct (e.g., truancy, running away).
- The court found evidence of routine physical abuse by staff, including beatings, slapping, and kicking, used as a disciplinary method.
- The court found use of isolation and restrictive “control” conditions as punishment, not limited to serious violence.
- The court found inadequate medical care, including lack of continuous nursing coverage at several facilities and an overall medical system insufficient for juveniles’ needs.
- The court found discriminatory separation practices, including racial segregation and segregation based on suspected homosexuality.
- The court found an absence of reliable grievance mechanisms and evidence that youths could face intimidation for reporting mistreatment.
- The court found deficiencies in staff screening and training that contributed to unsafe and abusive conditions.

## Issues

1. Whether disciplinary practices and conditions in TYC institutions (including physical abuse, isolation practices, inadequate medical care, and arbitrary discipline) violated juveniles’ constitutional rights under due process.
2. Whether segregation by race and by suspected homosexuality in TYC facilities violated equal protection.
3. Whether the State’s asserted rehabilitative purpose for juvenile confinement required a constitutionally adequate treatment environment and prohibited abusive, degrading, or retaliatory practices.

## Decision

- The district court granted injunctive relief against specified TYC practices deemed unconstitutional and likely to cause irreparable physical and psychological harm to the plaintiff class.
- The court ordered substantial reforms addressing discipline and use of isolation, physical punishment, medical services, discriminatory segregation, staff hiring/screening, and mechanisms for complaints and protection from retaliation.
- The court treated juveniles in state custody as retaining constitutional protections that limit the State’s authority to impose harsh or degrading conditions under a rehabilitative rationale.

## Legal Principles

- Juveniles involuntarily confined by the State retain constitutional protections; parens patriae and rehabilitative justifications do not permit abusive or arbitrary treatment.
- Routine physical brutality and harsh discipline in juvenile institutions are unconstitutional when excessive, arbitrary, or incompatible with basic standards of humane confinement.
- The Constitution constrains conditions and practices in juvenile facilities, including access to adequate medical care and limits on isolation and punitive control measures.
- Racial segregation and other discriminatory segregation without lawful justification violate equal protection norms in state institutions.
- Due process concerns are heightened where internal controls are ineffective; intimidation and lack of meaningful grievance channels can support injunctive relief to prevent abuse and arbitrariness.

## Conclusion

The court found that multiple practices and conditions in Texas juvenile training schools were unconstitutional and entered injunctive relief requiring institutional changes to discipline, isolation, medical care, segregation practices, staff selection, and complaint procedures to protect confined youths from abuse, discrimination, and arbitrary treatment.


Morales v. Turman, 364 F. Supp. 166 (E.D. Tex. 1973)