## Facts

- Iowa closed its girls’ training school and, through Iowa DHS Director Charles Palmer, contracted with Wisconsin to place Iowa delinquent girls at Copper Lake (a Wisconsin juvenile facility).
- Laera D. Reed and Paige Ray‑Cluney, both 16, were adjudicated delinquent by Iowa juvenile courts in 2015 and sent to Copper Lake under the interstate arrangement.
- The complaints alleged Copper Lake had high staff turnover, inadequate staffing and training, and a history of judicial criticism for harsh treatment of juveniles.
- Plaintiffs alleged they were subjected to prolonged isolation (“segregation”), received little or no meaningful education while isolated, were sprayed with mace multiple times, and both attempted suicide.
- Plaintiffs sued Palmer in his individual capacity under 42 U.S.C. § 1983, alleging he knew or should have known of serious risks and unconstitutional conditions at Copper Lake but continued contracting for placements without adequate protections.

## Issues

1. Whether the complaints plausibly alleged that Palmer’s conduct caused violations of the plaintiffs’ Fourteenth Amendment due process rights based on juvenile confinement conditions, including isolation and force.
2. Whether the asserted rights were clearly established at the time, such that Palmer was not entitled to qualified immunity at the Rule 12(b)(6) stage.

## Decision

- The Seventh Circuit reversed the dismissal and remanded.
- The court held it was premature to grant qualified immunity on a motion to dismiss given the need for factual development about what Palmer knew and did.
- Accepting the allegations as true, the court held the complaints plausibly alleged unconstitutional punishment of juvenile detainees through prolonged isolation and related conditions not reasonably tied to legitimate governmental objectives.
- The court rejected framing the “clearly established” inquiry so narrowly that it would require a prior case involving an out-of-state contracting official on materially identical facts.

## Legal Principles

- At the pleading stage, courts must accept well-pleaded factual allegations as true and draw reasonable inferences in the plaintiff’s favor; qualified immunity may be inappropriate where the defense turns on disputed inferences about knowledge and conduct.
- Under the Fourteenth Amendment, juvenile detainees may not be subjected to conditions that amount to punishment; restrictions not reasonably related to legitimate governmental objectives, or excessive in relation to those objectives, can violate due process.
- Prolonged, punitive isolation of juvenile detainees, particularly when not justified by legitimate objectives and accompanied by serious harm, can violate clearly established constitutional law.
- Section 1983 personal involvement can be shown by deliberate indifference where an official’s decisions knowingly expose individuals to a substantial risk of unconstitutional conditions, even if the official does not directly administer the facility.

## Conclusion

The court held that the plaintiffs’ allegations of prolonged juvenile isolation and related harms, combined with allegations that Iowa’s DHS director knowingly exposed them to those risks through interstate placements, were sufficient to defeat qualified immunity at the motion-to-dismiss stage and required further proceedings.


Reed v. Palmer, 906 F.3d 540 (7th Cir. 2018)