## Facts

- Conway Human Development Center (CHDC) is a state-operated residential institution for individuals with developmental disabilities.
- Following a federal investigation, the United States reported serious deficiencies at CHDC involving resident safety, medical and mental-health care, and restraint practices.
- The United States sued Arkansas and state officials for institutional conditions and service delivery at CHDC.
- The amended complaint asserted three claims: (1) unconstitutional conditions under the Fourteenth Amendment enforceable through CRIPA; (2) unjustified segregation under the ADA’s integration mandate; and (3) failure to provide children a free appropriate public education (FAPE) in the least restrictive environment (LRE) under IDEA.
- During the litigation, the Arkansas Department of Education (ADE) investigated CHDC’s educational services, found partial IDEA noncompliance affecting FAPE, ordered a corrective action plan, and began monitoring implementation.
- After denial of a preliminary injunction, the court held a six-week bench trial on the merits.

## Issues

1. Whether CHDC’s conditions and practices violated residents’ Fourteenth Amendment rights such that systemic relief was warranted under CRIPA.
2. Whether Arkansas violated the ADA integration mandate by unnecessarily institutionalizing CHDC residents rather than serving them in more integrated settings.
3. Whether CHDC failed to provide children with disabilities a FAPE in the LRE under IDEA, and whether equitable relief was warranted given ADE’s ongoing corrective process.
4. Whether Arkansas, as a prevailing party on most claims, could recover attorneys’ fees against the United States under 42 U.S.C. § 1997a(b), and under what standard.

## Decision

- The court entered judgment for Arkansas on the Fourteenth Amendment/CRIPA claim, finding the United States did not prove unconstitutional conditions.
- The court entered judgment for Arkansas on the ADA claim, finding the United States did not prove unjustified segregation in violation of the integration mandate.
- The court found an IDEA violation in part: CHDC educated children in the LRE but failed to provide FAPE.
- The court declined to issue injunctive relief on the IDEA violation, concluding ADE’s enforcement, corrective action plan, and monitoring made a federal injunction unnecessary.
- In a later fee decision, the court denied Arkansas’s request for attorneys’ fees, applying a “frivolous, unreasonable, or without foundation” standard to fees sought against the United States.

## Legal Principles

- Fourteenth Amendment conditions-of-confinement liability in institutional settings requires proof meeting the substantive due process threshold; identified deficiencies do not establish a constitutional violation absent sufficient proof of unconstitutional practices.
- ADA integration-mandate relief requires proof that individuals are appropriate for, and not opposed to, more integrated settings and that the state’s practices amount to unjustified segregation.
- IDEA distinguishes between LRE placement and the substantive adequacy of educational benefit (FAPE); compliance with LRE does not preclude a finding that FAPE was denied.
- Equitable relief may be withheld despite a proven statutory violation when a competent statutory enforcement authority is already implementing corrective measures likely to achieve compliance.
- Under 42 U.S.C. § 1997a(b), a prevailing defendant seeking fees against the United States must meet the heightened Christiansburg standard; fees are not awarded merely because the government failed to prevail.

## Conclusion

The court rejected the federal government’s constitutional and ADA challenges to CHDC, found a limited IDEA violation for failure to provide FAPE while upholding LRE compliance, and denied injunctive relief because state educational authorities were already enforcing corrective action; it later denied the State’s fee request because the federal case was not frivolous.


United States v. Arkansas, 794 F. Supp. 2d 935 (E.D. Ark. 2011)