## Facts

- Juveniles confined at the Indiana Boys’ School brought a class action under 42 U.S.C. § 1983 against state corrections officials.
- The institution housed boys ages 12–18; a substantial portion were noncriminal offenders; population exceeded stated capacity.
- Staffing for mental and medical care was limited, including minimal psychiatric presence.
- Plaintiffs challenged two practices: (1) corporal punishment via paddlings causing bruises, welts, and other serious injuries; and (2) administration of tranquilizing “control” drugs primarily to manage behavior rather than to treat diagnosed conditions, with inadequate medical examination and treatment planning.
- Plaintiffs also alleged the institution failed to provide adequate rehabilitative treatment despite the stated rehabilitative purpose of juvenile commitment.
- The district court enjoined corporal punishment and the challenged drug-administration practices as cruel and unusual punishment and entered a declaratory judgment recognizing a constitutional right to adequate rehabilitative treatment.
- Defendants appealed both the injunction and the declaratory judgment.

## Issues

1. Whether the corporal punishment practices at the Indiana Boys’ School constituted cruel and unusual punishment under the Eighth Amendment as applied through the Fourteenth Amendment.
2. Whether administering tranquilizing drugs as a behavior-control measure, without adequate medical justification and oversight, constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments.
3. Whether juveniles committed to a state institution for rehabilitation have a Fourteenth Amendment due process right to adequate rehabilitative treatment.

## Decision

- The Seventh Circuit affirmed the injunction barring corporal punishment as practiced at the institution.
- The court affirmed the injunction barring the method of administering tranquilizing drugs as practiced at the institution.
- The court affirmed the declaratory judgment that juveniles confined at the Boys’ School have a constitutional right to adequate rehabilitative treatment.

## Legal Principles

- The Eighth Amendment (through the Fourteenth) prohibits institutional punishments that are excessive, unnecessary, and inflict serious physical harm, including in juvenile facilities.
- Using medication primarily as a punitive or coercive control mechanism, without individualized medical judgment and adequate professional oversight, can constitute cruel and unusual punishment.
- When the state confines juveniles in an institution justified as rehabilitative, due process requires the state to provide adequate rehabilitative treatment consistent with the purpose of the commitment.

## Conclusion

The Seventh Circuit held that severe paddling and behavior-control drugging of confined juveniles violated the Eighth and Fourteenth Amendments and that juveniles committed for rehabilitation possess a due process right to adequate rehabilitative treatment, affirming both injunctive and declaratory relief.


Nelson v. Heyne, 491 F.2d 352 (7th Cir. 1974)