## Facts

- Juveniles involuntarily committed to the Texas Youth Council (TYC) brought a certified class action against TYC officials and staff.
- The suit began in 1971 seeking private access to counsel and expanded to challenge conditions, programs, and procedures across TYC institutions.
- The district court granted broad access to TYC facilities for investigation.
- In 1973, the district court entered a preliminary injunction based on findings tied to cruel and unusual punishment and a claimed right to treatment.
- After a six-week trial, the district court in 1974 found systemic constitutional violations (including cruel and unusual punishment and due process violations) and imposed detailed, system-wide minimum standards governing confinement and institutional practices.
- The Fifth Circuit initially required a three-judge court under former 28 U.S.C. § 2281; the Supreme Court summarily reversed, holding a three-judge court was unnecessary.
- On remand, the Fifth Circuit addressed whether continued broad injunctive relief remained justified given defendants’ claims of significant post-trial reforms within TYC.

## Issues

1. Whether the district court’s extensive, system-wide injunction regulating TYC institutions could remain in force on the existing record despite claimed material changes in TYC conditions since trial.
2. Whether ongoing federal equitable supervision should be reconsidered and tailored based on updated findings regarding current constitutional compliance.

## Decision

- The Fifth Circuit did not fully affirm or vacate the 1974 remedial orders on the existing record.
- The court remanded to the district court for a further evidentiary hearing on changes that had occurred at TYC since the trial.
- The court indicated that if conditions had improved to the extent claimed, continued injunctive relief might be inappropriate and the decree could require narrowing or termination.
- The court emphasized that the scope of any continuing decree must correspond to present conditions and current need for prospective relief.

## Legal Principles

- Prospective equitable relief must address present and future violations, not function as a sanction for past misconduct.
- Structural injunctions over state institutions require periodic reassessment when defendants plausibly show materially changed conditions.
- A remedial decree must be supported by current factual findings and remain no more extensive than necessary to cure ongoing constitutional violations.
- Federal courts may impose institutional remedies for proven constitutional violations, but continued intrusive supervision must be justified by up-to-date evidence and sensitivity to state administration.

## Conclusion

The Fifth Circuit required the district court to reassess the need and scope of the TYC institutional-reform injunction based on current conditions, remanding for updated findings and signaling that substantial improvements could warrant modification or dissolution of prospective relief.


Morales v. Turman, 562 F.2d 993 (5th Cir. 1977)