## Facts

- Washington courts may order competency evaluations when there is reason to doubt a criminal defendant’s competence to stand trial.
- The Washington State Department of Social and Health Services (DSHS), through state psychiatric hospitals, was responsible for providing (1) court-ordered competency evaluations (often while defendants remained in jail) and (2) inpatient competency restoration for defendants found incompetent.
- Pretrial detainees in Washington jails experienced weeks- or months-long delays waiting for evaluations or transfer to a hospital for restoration.
- After a bench trial, the district court found the delays were systemic and tied to inadequate bed capacity, staffing, funding, and planning.
- The district court found jail confinement during the delays caused deterioration in detainees’ mental health and was not a substitute for therapeutic evaluation or treatment.
- Plaintiffs (including individual detainees and a protection-and-advocacy organization) brought a § 1983 class action alleging the delays violated the Fourteenth Amendment’s Due Process Clause.

## Issues

1. Whether systemic delays in providing court-ordered competency evaluations and competency-restoration services to pretrial detainees violate substantive due process.
2. Whether the district court’s injunctive relief, including fixed deadlines and detailed remedial requirements, was properly tailored under federal equitable principles and the Prison Litigation Reform Act (PLRA).

## Decision

- The Ninth Circuit affirmed the liability determination that DSHS’s systemic delays in providing competency evaluations and restoration services violated substantive due process.
- The Ninth Circuit affirmed in part and vacated in part the injunction.
- The court held that imposing enforceable deadlines can be an appropriate remedy where the constitutional injury is the length of the delay.
- The court vacated provisions of the injunction that were insufficiently tailored and remanded for modification consistent with the PLRA’s limits on prospective relief.

## Legal Principles

- Pretrial detainees held for competency evaluation or restoration have a substantive due process right to timely access to the evaluation or treatment that justifies their confinement.
- Administrative difficulty and resource constraints do not, by themselves, supply a sufficient governmental justification for prolonged jail detention that causes serious harm to mentally ill detainees awaiting court-ordered services.
- Federal courts may grant structural injunctive relief to remedy ongoing constitutional violations, including setting practical and effective time limits for constitutionally required services.
- Under the PLRA, prospective relief must be narrowly drawn, extend no further than necessary to correct the violation, and be the least intrusive means to correct the violation.

## Conclusion

The Ninth Circuit held that Washington’s systemic delays in providing court-ordered competency evaluations and inpatient restoration to pretrial detainees violated substantive due process, and it allowed deadline-based relief while requiring the district court to narrow overbroad remedial provisions to comply with the PLRA.


Trueblood v. Wash. State Dep’t of Soc. & Health Servs., 822 F.3d 1037 (9th Cir. 2016)